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Legal Disclosure

Information in accordance with section 5 TMG

DelighteX GmbH
Christoph-Rapparini-Bogen 25
80639 Munich
Germany

Handelsregisternummer: HRB 211204, Amtsgericht München
Managing director: Evgeny Belyaev

Disclaimer

Accountability for content

The contents of our pages have been created with the utmost care. However, we cannot guarantee the contents' accuracy, completeness or topicality. According to statutory provisions, we are furthermore responsible for our own content on these web pages. In this context, please note that we are accordingly not obliged to monitormerely the transmitted or saved information of third parties, or investigate circumstances pointing to illegal activity. Our obligations to remove or block the use of information under generally applicable laws remain unaffected by this as per §§ 8 to 10 of the Telemedia Act (TMG).

Accountability for links

Responsibility for the content of external links (to web pages of third parties) lies solely with the operators of the linked pages. No violations were evident to us at the time of linking. Should any legal infringement become known to us, we will remove the respective link immediately.

Copyright

We may need to collect and process Personal Information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Last updated: December 2021

CoSpaces Edu’s Terms of Use

CoSpaces Edu’s mission is to create an environment where students can excel and be their best. To accomplish this goal, it is essential that CoSpaces Edu provides a safe place for students’ creations and that teachers are in complete control over how that information is shared.

These Terms of Use govern your use of Delightex’ websites at cospaces.io/edu, the CoSpaces Edu Application (edu.cospaces.io) and the CoSpaces Edu Mobile Applications (collectively “the CoSpaces Edu Service”, “the Service” or “CoSpaces Edu”). CoSpaces Edu is owned and operated by DelighteX GmbH (“Delightex”).

By creating an account on CoSpaces Edu, the User agrees to be bound by the Terms of Use (“Terms”).

CoSpaces Edu is intended for use in schools only. If the user is not a school or if the user intends to use the service in conjunction with or as part of a paid service or product, for the purpose of marketing its own or someone else’s products or services or otherwise in conjunction with a commercial event such as a workshop, online courses or broadcasted events, the user must enter into a separate agreement with Delightex.

1. CoSpaces Edu is COPPA, FERPA and GDPR compliant

Data collected by CoSpaces Edu may include personally identifiable information from education records that are subject to the U.S. Family Educational and Privacy Act (FERPA) ("FERPA Records"). To the extent that Student Data includes FERPA Records, CoSpaces Edu will be considered a "School Official" (as that term is used in FERPA and its implementing regulations) under the direct control of the school with regard to the use and maintenance of the FERPA Records and will comply with FERPA.

CoSpaces Edu only collects personal information through the Services from a student where their school, district, and/or teacher has agreed (via the terms described in more detail below) to obtain parental consent to use the Services and disclose personal information to us for the use and benefit of the learning environment. Such consent shall not be deemed as consent pursuant to Art. 6 (1) a) GDPR.

If the User is aware that CoSpaces Edu is collecting information from a student without parental consent, the User shall contact Delightex immediately at info@delightex.com and Delightex will delete the data.

2. Use of CoSpaces Edu

Using CoSpaces Edu requires a registration and acceptance of these Terms of each individual using the Service (“User”) under cospaces.io/edu (“Website”). The Service offers Teacher Accounts and Student Accounts. When registering with the Software, the User may decide, whether the account shall be set up as Teacher Account or Student Account. To learn more about the major functionalities of CoSpaces Edu please refer to the Website.

CoSpaces Edu may be operated on any computer with an up-to-date web browser software (i.e. Chrome, Safari or Firefox), mobile device with an up-to-date iOS or Android operating system. To use CoSpaces Edu on an iOS or Android device, the User will have to download the CoSpaces Edu app from the relevant app store and accept the Terms and Conditions of that app store. Using CoSpaces Edu requires the User to establish an appropriate Internet Connection, for which usual transmission costs may apply.

A copy of the Terms applicable at the moment of accepting these Terms is available for download as PDF under https://cospaces.io/edu/terms-of-use.pdf. Delightex does not store or grant the User access to these Terms afterwards.

2.1 Teacher Accounts

Only teachers or school administrators (“Teachers”) can create a Teacher Account on CoSpaces Edu, and may invite Students (as defined below) to use the Services and administer Classes (as defined below). Creating an account as Teacher is only allowed to users who are of the age 18 or older.

Teachers create an Account by selecting “Teacher” on the registration page and following the registration process. The Teacher is required to confirm to be of the age 18 or older and will be presented the present Terms. If the Teacher agrees with the present Terms, the Teacher is asked to enter its Name and its email address and to choose a user name and a password. After clicking on “Create Account”, the Teacher receives a confirmation email, where the Teacher shall confirm its registration by clicking a confirmation link within the confirmation email. By clicking on “Create Account”, the Teacher issues a binding offer to enter into an agreement concerning the use of CoSpaces Edu as Teacher pursuant to the provisions of these Terms. Delightex accepts the Teacher’s offer by informing the Teacher of the successful registration with the Service after the Teacher clicked the confirmation link. The acceptance of the Teacher’s offer is at the sole discretion of Delightex.

2.2 Student Accounts

Individuals, who were invited by their Teacher (“Students”), create an account by selecting “Student” on the registration page and following the registration process. The Student is required to enter the invite code provided by the Teacher. Students may use CoSpaces Edu only if their parent or legal guardian has given permission to the Teacher or their school. A Student may use CoSpaces Edu only if the Student has been given an Invite Code or has otherwise been invited to use CoSpaces Edu by the Teacher.

CoSpaces Edu is an extension of the classroom. The Student agrees to use CoSpaces Edu in a manner that is appropriate to the classroom. The Student may not violate the policies of the school or school district in the Student’s use of CoSpaces Edu

2.3 Classes

Teachers can create a virtual class on CoSpaces Edu, where Students can create, edit, upload, view, and share work (“Class”). Once the Class is created, Teachers can invite Students and additional faculty with appropriate permissions to join the Class.

Teachers and schools agree to obtain written consent from parents of students prior to their students creating accounts on CoSpaces Edu. Alternatively Teachers and Schools may act as the Student’s parent's agent and provide consent to use CoSpaces Edu solely in the educational context (as provided in https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Schools). In case of the latter, the Teacher shall be authorized by the Students’ parents accordingly. The Teacher should consult with its school or school district to ensure that the Teacher obtains proper consent to use CoSpaces Edu in the classroom.

When the Teacher creates a CoSpaces Edu class, the Teacher agrees that:

  • Any Students added to the Class by the Teacher are current students attending the Teacher’s class in the school where the Teacher is employed.
  • Any additional Teachers added to the Class are authorized by the Teacher’s school to access student creations.
  • The Teacher will use CoSpaces Edu only for lawful purposes and abide by applicable law and policies issued by the school and/or the school district in the Teacher’s use of CoSpaces Edu.
  • The Teacher will treat CoSpaces Edu as an extension of the classroom and takes reasonable steps to confirm that Students are using CoSpaces Edu appropriately.
  • The Teacher will take reasonable measures to protect access to information contained in Student creations.

3. CoSpaces Edu Plans

For Students, using the Services is always free. For Teachers CoSpaces Edu services are available as paid or free services (“Plans”) and the Teacher agrees to abide by the terms applicable to the Plans the Teacher signed up for. The number of Students and other Teachers the Teacher is allowed to add to its Classes (“Seats”) and the features available within CoSpaces Edu are subject to the Plans and/or add-ons chosen by the Teacher:

3.1 CoSpaces Edu Basic

The CoSpaces Edu Basic Plan (“Basic Plan”) does not require payment and allows one Teacher to use the Basic Plan with up to 29 Students. The Teacher can create one Class and one assignment with limited assets and features available to him or her. If the Teacher was using CoSpaces Edu Pro before and the Plan expired, he or she will have view-only access to CoSpaces that were created during the usage of CoSpaces Edu Pro.

3.2 CoSpaces Edu Pro

The CoSpaces Edu Pro Plan (“Pro Plan”) requires payment before the Teacher can access it. If the Teacher activated the Pro Plan, further features may become accessible that are not available through the Basic Plan. More information about CoSpaces Edu Plans, the pricing and features can be found under: https://cospaces.io/edu/pricing.html).

The Pro Plan can be purchased with a set amount of seats and is valid for 365 days upon date of purchase. There may be limitations to the amount of seats set for a Pro Plan.

It is possible to add Seats or add-ons at any time during the validity of the Pro plan, in which case the cost is prorated until the expiration date of the Plan and there is a minimum transaction fee set. It is not possible to reduce the amount of seats or remove add-ons during this time.

On the expiration date, the Pro Plan becomes inactive. The Teacher may choose to renew the Pro Plan or downgrade to the Basic Plan.

4. Payments

The Pro Plan can be purchased and is pre-paid directly from the CoSpaces Edu web application, through in-app purchase in the CoSpaces Edu iOS mobile application or through a separate agreement with Delightex, and is non-refundable.

If the Pro Plan is not paid on time, Delightex reserves the right to deactivate your Pro Plan or suspend your account.

5. Pricing

Delightex may change the price for CoSpaces Edu Pro from time to time, and will communicate any price changes to the Teacher via newsletter at least four weeks in advance.

Delightex does not provide any refunds if the price for a Pro Plan drops, or if Delightex offers subsequent discounted promotional pricing ("Discount Codes") or changes the content or features of a Pro Plan.

If the Discount Code is not entered at the time of purchase as specified, the purchase will not be eligible for the discounted pricing and cannot be refunded.

6. Taxes

Prices listed may not include sales or value added tax and applicable tax may be calculated and added only when the transaction is completed. Depending on where the Pro Plan is purchased, such tax may only be visible on the final invoice of the purchase. In certain jurisdictions, local laws require that prices include all applicable taxes, in which case this will be indicated at the time of purchase.

7. Pre-paid Offers

If the User has received a code or other offer provided or sold by or on behalf of Delightex for access to CoSpaces Edu Pro (“Code”), separate terms and conditions presented along with the Code (“Pre-Paid Terms”) may apply to the User’s access to the Service and the User agrees to comply with any such Pre-Paid Terms. If provisions of the Pre-Paid Terms deviate from provisions of these Terms, the provisions of the Pre-Paid Terms shall prevail.

Codes purchased from third parties or through other platforms (e.g. Google Play or Apple App Store) are subject to the refund policies of those platforms. Delightex cannot be held responsible for these platforms’ policies.

8. Trials

Delightex may, at its own sole discretion, offer trials of CoSpaces Edu Pro for a specified period without payment (“Trial”). Delightex reserves the right to revoke the Trial and put the User’s account on hold in the event that Delightex determines that the User is not eligible.

9. Deleting an Account

Teachers can delete their CoSpaces Edu accounts under the account settings. Students may have their accounts deleted through any Teacher who sent them a CoSpaces Edu invite code or a school administrator or by sending an email to support@cospaces.io. Students who have a CoSpaces Edu account and would like this account to be deleted may contact Delightex directly at support@cospaces.io to have the Student’s account deleted. The same applies to the Student’s legal guardians.

10. Privacy

Delightex takes the privacy of its Users seriously. To learn more about how Delightex collects, stores, uses, shares, and protects personal information, please review the Privacy Policy at https://cospaces.io/edu/privacy-policy.html.

11. Your Intellectual Property

Delightex does not own the content Users provide – Students and their schools own all Student Data added to CoSpaces Edu.

However, in order to provide the Services, Delightex needs certain limited rights to the content uploaded and/or created by Users or content provided by Delightex, which the User modifies within CoSpaces Edu (“User Generated Content”). For example, when a User uploads content, Delightex needs the rights to store it and serve it back to the Users.

Therefore Users grant Delightex the non-exclusive right to use, publish, transmit, display, copy, process, adapt, modify, and distribute the User Generated Content to the extent necessary to use the User Generated Content within the context of the CoSpaces Edu Service. The grant of rights is not limited in terms of time and includes the right of Delightex to use the User Generated Content and make it available to other Users, including Users, which are not participating in the same Class.

The User warrants to have the right to use the User Generated Content with CoSpaces Edu. The User will indemnify Delightex upon first request, if any third party is making claims against Delightex due to using User Generated Content without having the rights thereto. The User will further either delete the User Generated Content or acquire the rights required to use the User Generated Content without infringing any third party rights. The User shall inform Delightex immediately when the User becomes aware of any third party claims.

12. CoSpaces Edu’s Intellectual Property

CoSpaces Edu is protected by copyright, trademark, and other intellectual property laws. Delightex grants the User a limited, non-exclusive, non-transferable non-sublicensable license to view, copy, and display CoSpaces Edu solely in connection with the User’s permitted use of CoSpaces Edu over the internet as Software-as-a-Service. The grant of right is limited timewise to the period the User uses the Service. Any rights not expressly granted here are reserved.

Unauthorized use of CoSpaces Edu’s logos, trademarks, copyrights, domain names, or other distinctive brand features is prohibited.

13. Prohibited Activities and Etiquette

All Users agree that they will refrain from any activities that are violating applicable laws, infringing third party rights or violating any principles of youth protection when using CoSpaces Edu. In particular it is prohibited to:

  • upload, distribute, offer or promote content which violates youth protection legislation, privacy laws or other statutory provisions, pornographic material and/or fraudulent content,
  • use CoSpaces Edu to distribute unsolicited or unauthorized unsolicited communications, promotions, advertisements or spam,
  • make available, distribute or use content that is protected by law or third party rights without having the authority thereto or
  • make available or publish content which might insult or defame any third party.

Regardless, whether or not the activity is prohibited, the User further agrees to commit to the following rules of etiquette when using CoSpaces Edu:

  • Don’t use CoSpaces Edu in any manner that would be inappropriate for the classroom or violates applicable school or school district policies.
  • Don’t use CoSpaces Edu to lie or mislead other users.
  • Don’t use CoSpaces Edu to do anything threatening, abusive, harassing, defamatory, tortious, obscene, profane, or invasive of another person’s privacy.
  • Don’t do anything that interferes with the proper functioning of any software, hardware, or equipment that belongs to CoSpaces Edu or anyone else.
  • Don’t impersonate CoSpaces Edu or Users on CoSpaces Edu or elsewhere.
  • Don’t interfere with anyone’s use or enjoyment of CoSpaces Edu.
  • Don’t use personal information about other users, including students, without consent or as forbidden by applicable law or regulation.

14. Account Usage

The use of CoSpaces Edu requires a CoSpaces Edu account and password (“Credentials”). The User shall keep the Credentials confidential and shall take appropriate measures to prevent third persons to become aware of the Credentials. It is not permitted for any reason whatsoever to provide the Credentials to any other person or using any other person’s Credentials. CoSpaces Edu allows a maximum of 1 computer device and a maximum of 2 mobile devices to be logged into the same account simultaneously.

15. Account Suspension and Termination

Delightex reserves the right to suspend or terminate accounts associated with Users who engage in any of the prohibited activities described above or in any manner that otherwise violates the Terms or other policies.

16. Account Transfer

If the User signed up as a Teacher with a school provided email address, and the Teacher’s school later signs up for a CoSpaces Edu school account, Delightex may transfer the Teacher’s account to be under the management and control of the Teacher’s school. To protect student data, in certain limited circumstances (such as when a Teacher leaves a school) Delightex may transfer a Class to a different Teacher if Delightex receives a properly authorized request from the relevant school.

17. Abandoned Accounts

Delightex reserves the right to terminate accounts that have not been accessed by the Teacher or school associated with the account for a period of more than one year. Prior to terminating an abandoned account, Delightex will notify the Teacher or school associated with the account by email.

18. Security

Delightex uses industry best practices to collect, store, and transmit data securely. This includes data centers with stringent physical access control measures, use of HTTPS/SSL to securely transmit data, and routine audits of Delightex’ security protocols. In the event of a security breach, Delightex will notify affected Users as required by law so that the User can take steps to keep their data safe.

19. Changes to the Terms

Delightex may modify the Terms from time to time. Delightex will notify the User of any changes to the Terms by email at least two weeks before such change becomes binding. If the User continues to use CoSpaces Edu after the User received such a notice, the User agrees to be bound by any changes to the Terms.

20. Warranties and Disclaimers

Insofar as the following provisions do not state otherwise, Delightex operates the Services in accordance with legal warranty rights.

Delightex operates the Services as specified in these Terms or the specifications on the Website. Delightex’ liability without fault pursuant to § 536a German Civil Code (BGB) shall be excluded. The Services do not include the storage and backup of any data, i.e. User Generated Content. It is in the sole responsibility of the User to regularly backup the data uploaded to and created with CoSpaces Edu.

The availability of the Services averages at 99 percent per year within the sphere of influence of Delightex. The Services are available if the User is able to use its major features. If the service is suspended due to necessary maintenance works or force majeure such times shall not be considered for the calculation of the availability.

The availability of the Services shall be calculated according to the following formula:

Availability = 100 - Unscheduled Downtime x 100 / Agreed service time in hours

21. Limitation of Liability

Any liability of Delightex shall be excluded. The limitation of liability shall not apply in the event of a breach of material contractual obligations. Material contractual obligations shall be any obligation the fulfilment of which is essential to proper performance of the contract in the first place and compliance with which the User may regularly rely on and the breach of which on the other hand endangers the achievement of the contractual purpose. In the event of a slightly negligent breach of a material contractual obligation, Delightex’ liability shall be limited to the foreseeable damage typically for the kind of contract.

The limitation of liability shall further not apply, if the damage was caused intentionally or by gross negligence or for damages resulting from mortal injury, physical harm or health damage.

Delightex shall also be liable for damages based on the absence of a warranted characteristic or for which liability is provided under the German Product Liability Act.

22. Governing Law / Jurisdiction

The Services are controlled by Delightex from its offices located in Munich, Germany. They can be accessed by most countries around the world. As each country has laws that may differ from those of Germany, by accessing the Services, the User agrees that the statutes and laws of the Federal Republic of Germany, without regard to the conflict of laws and the United Nations Convention on the International Sales of Goods, will apply to all matters relating to the use of the Services and the purchase of any products or services through the Services.

Furthermore, Users, which are not consumers and for consumers, whose place of general jurisdiction is not within Federal Republic of Germany, shall bring in any action to enforce these Terms in the courts located in Munich-City, Germany.

23. Informal Dispute Resolution

Delightex wants to address the User’s concerns without needing a formal legal case. Before filing a claim against CoSpaces Edu, the User agrees to try to resolve the Dispute informally by contacting info@delightex.com. Delightex will try to resolve the Dispute informally by contacting the User through email.

The European Commission operates a dispute settlement procedure for online dispute resolution with consumers pursuant to Art. 14 Para 1 Regulation (EU) 524/2013 under http://ec.europa.eu/consumers/odr).

Delightex is not legally required to participate in dispute settlement before a consumer arbitration board. Delightex endeavors to find a mutually acceptable solution in the event of a conflict with a User. Since arbitration bodies charge fees, Delightex does also not voluntarily take part in a dispute settlement procedure before a consumer arbitration board in the well understood financial interests of the User.

24. Feedback and Customer Service

Delightex welcomes feedback and suggestions about CoSpaces Edu. Please email us at support@cospaces.io at any time.

25. Entire Agreement

These Terms (and any other policies referred to in this document) make up the entire agreement between the User and Delightex and supersede any prior agreement. If any part of these Terms are found to be unenforceable by a court or arbitrator, the remaining parts will remain in full force and effect. If Delightex fails to enforce any part of these Terms, such failure does not constitute a waiver.

Contact Information

DelighteX GmbH
Christoph-Rapparini-Bogen 25
80639 Munich, Germany
info@delightex.com

Last updated: April 2024

Data privacy statement - CoSpaces Edu product

Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. Our services have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our App, what happens with these data and how you may object to data usage.

1 General information on data processing

1.1 Person Responsible (Controller)

Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:

Delightex GmbH​
Address:​
 Christoph-Rapparini-Bogen 25, 80369 Munich, Germany
Email:​
info@cospaces.io
Homepage:
CoSpaces Edu – in the App Store (apple.com) / CoSpaces Edu – in Google Play /​  cospaces.io

1.2 Name and address of the Data Security Officer

The data protection officer is:
Kemal Webersohn of WS Datenschutz GmbH

If you have questions about data protection, you can contact WS Datenschutz GmbH at the following email address: delightex@ws-datenschutz.de

WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

webersohnundscholtz.de

1.3 Protection of your data

We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.

If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (data processing agreement) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

We maintain a comprehensive privacy and security program that is aimed to protect the security, confidentiality, and integrity of your personal data at all times. We always consider privacy and security when developing or improving CoSpaces Edu and comply with applicable laws. We also provide resources on these topics to our users.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons. Our App is SSL/TLS encrypted, as can be seen by the https:// at the start of our URL.

We do not collect, maintain, use or share personal data beyond that needed to run our application.

We do not sell personal data or any other data.

We do not advertise to students through our application.

1.4 Erasure of personal data

We process personal data only if necessary in order to run our application. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

1.5 CoSpaces Edu & COPPA

The Children’s Online Privacy Protection Act (COPPA) protects personal information belonging to a child younger than 13. We do not require users younger than 13 to disclose more information than is reasonably necessary to use our services and have taken measures to ensure that the COPPA requirements are met by us, as well as by external service providers we work with.

1.6 CoSpaces Edu & FERPA

The data collected by us includes student data that may be subject to the Family Educational Rights and Privacy Act (FERPA), such as student names or student-generated content. For that matter, we have taken measures to comply with FERPA requirements and ensured that external service providers also meet the requirements to this extent.

2 Use of data on this App and in log files

2.1 Scope of processing personal data

When visiting our App, AWS web servers temporarily store every access in a log file. The following data may be collected and stored by AWS until automated erasure:

  • Date and time of access
  • Name and URL of the retrieved file
  • Transmitted amount of data
  • Message if the retrieval was successful
  • Detection data of the browser and operating system used

We do not access or analyze this data, which is stored on AWS servers.

We use the services of AWS for hosting purposes. The data processing is carried out by: Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, Luxembourg 1855, Luxembourg (a subsidiary of Amazon.com Inc., 410 Terry Avenue North, Seattle WA 98109, USA).

AWS hosting services are used to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offer.

You can find more information on the data protection of the service provider here: https://aws.amazon.com/de/privacy/

2.2 Legal basis for processing personal data

The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our App accessible for you.

2.3 Purpose of data processing

The processing of this data serves: the purpose of enabling the use of the App (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the App. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.

2.4 Duration of storage

As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out. This happens as soon as you close our App. Our hosting service, Amazon Web Services (AWS), might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service will delete this data after a period of 6 months.

2.5 Right of objection and erasure

The data processing is necessary in order to present the App and to ensure the App’s operation. Therefore, objecting is impossible.

3 Use of cookies

3.1 Description and scope of data processing

Our App uses cookies. This means that when using the App, cookies are stored on your computer. Cookies are small text files which are assigned to the browser you are using and which are stored on your hard drive. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your device. The following data may be transmitted:

  • Your last session ID (encrypted)

3.2 Legal basis for data processing

The legal basis for the processing of data for cookies, which serve only the functionality of this App, is Art. 6 para. 1 s. 1 lit. f) GDPR.

3.3 Purpose of data processing

Our legitimate interests are to provide you with a working App connection and to ensure a comfortable use of this App.

3.4 Duration of storage

Session cookies are deleted when you log out or close the App.

3.5 Right to objection and erasure

We only use cookies that are technically necessary to provide you with our services. The use of these is indispensable, which is why it is not possible to object in this case, otherwise the app cannot be used.

4 Data processing during download

4.1 Description and scope of data processing

When you download our app, the Google Play Store and iOS AppStore require specific information from you and the following data will be transferred:

  • Username
  • E-mail address
  • Customer number of your account
  • Time of download
  • Device identification number

4.2 Note on requesting location data

We would like to point out that when using our apps, the so-called "Coarse Location Permission" can be requested from the user. This is one of the confidential Android or iOS permissions. This authorization request is displayed graphically with a system dialog within the app and must be issued/confirmed by the user. This is a security feature of Google and Apple. This gives Cospaces permission to determine the approximate user location. However, we do not use this permission to determine the approximate location of the user. However, it is possible that Google and Apple process this data. The possible data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google's privacy policy can be found at: https://www.google.com/policies/privacy/ Apple Inc., 1 Apple Park Way, Cupertino, California, United States.Apple’s privacy policy can be found at: https://www.apple.com/legal/privacy/

4.2.1 Legal basis for data processing

The processing of this data takes place on the basis of Art. 6 para. 1 sentence 1 lit. a) GDPR.

4.2.2 Purpose of data processing

The data processing by Google and Apple takes place for the purpose of enabling the use of the app. It is used for system security at Google and Apple.

4.2.3 Duration of data processing

According to Google and Apple, the personal data will be deleted as soon as they are no longer required for the above-mentioned purposes.

4.2.4 Right to objection and erasure

The collection of data for the provision of the app is intended for the operation of the app by Google and Apple as a security feature. If you have any questions about data protection, you can contact Google using the following contact form: https://www.google.de/contact/ or contact Apple using the following contact form: https://support.apple.com/contact

5 Registration

5.1 Description and scope of data processing

The data subject can register in our App. This requires the data subject to enter personal data in the registration form. Depending on whether you register with us as a student or teacher, we process the following data:

Registration as a teacher:

  • Name (required)
  • Username (required)
  • Email address (required)
  • Chosen password (required)
  • Financial information (required when purchasing CoSpaces Edu Pro License Plans “the Paid Subscriptions”)

Registration as a student:

  • Email address
  • Username (required)
  • Chosen password (required)

The information provided by the data subject in the registration mask will be used exclusively for processing and will not be disclosed to third parties.

5.2 Legal basis for data processing

If the data subject enters required personal data in the registration form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in the optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

The sending of emails about your registration information is based on Art. 6 para. 1 s. 1 lit. b) GDPR.

5.3 Purpose of data processing

The processing of personal data is used solely for us to finish your registration and organize your App account.

5.4 Duration of storage

The data are deleted as soon as the purpose of storage is no longer required. This is the case if you delete your account and no statutory or regulatory retention periods of erasure contradict. Your data will be stored according to your respective location on servers located either in Europe, the United States or Asia Pacific. A list of countries and their respective server locations can be found under https://cospaces.io/edu/server-regions.html

5.5 Right to objection and erasure

During and after the registration, the data subject is free to change, correct or delete their personal data.

6 Third-party login

6.1 Description and scope of data processing

If you already own an account on Apple, Clever, Google, Microsoft or NAVER, you can register with your account (Third-Party Login). By doing so, you will be linking your account to your CoSpaces account and can also sign up on our web app with your third party-account in the future.

Following data will be provided to us from your chosen third-party account (Apple Inc., Clever Inc., Google LLC., Microsoft Corporation, NAVER Corp.):

  • Account-ID
  • First name
  • Last name
  • E-mail address
  • Verification of your third-party account
  • Link to your public profile at the chosen platform provider
  • If you use Google or Clever for your login: Username

For more information regarding each third-party login, the transmitted data and the data privacy settings of your account, we refer to the following data policies of each account provider:

Apple: https://www.apple.com/legal/privacy/de-ww/

Clever: https://clever.com/trust/privacy/policy

Google: http://www.google.com/policies/privacy/?hl=de

Microsoft: https://privacy.microsoft.com/de-de/privacystatement

NAVER: https://policy.naver.com/policy/privacy_en.html

In our continuous effort to improve the user experience and simplify the use of our services, we have introduced an integration with Google Classroom. This integration allows teachers to create and manage "CoSpaces assignments" through their Google Classroom classes.  To use this feature, the admin of the license plan must enable the Google Classroom integration under the license plan settings first. Once enabled, teachers that are a part of the same license plan will be able to access Google Classroom features to manage their class assignments efficiently.

We would like to emphasize that the protection and security of our users' personal data is of the utmost importance. When using the Google Classroom integration, no personal data of students or teachers is collected or shared without their explicit consent. The data required for the functionality of the integration is processed in accordance with our privacy policy and Google's privacy policy. 

We encourage users to read Google's privacy policy to gain a full understanding of how their data is handled as part of this integration.

6.2 Legal basis for data processing

As far as we receive your first and last name as well as your e-mail address, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. All further information is given to us voluntarily. Therefore, data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

6.3 Purpose of data processing

The third-party login facilitates the use of our registration function. We also use third-party logins to make our website better known.

6.4 Duration and storage

Third-party login data is stored until the declaration of a revocation and used as described.

6.5 Right to objection and erasure

You can prevent this data processing by using our regular registration process. During and after the registration, the data subject is free to change, correct or delete their personal data. As far as the data processing is based on your consent, you can withdraw your consent to this data processing at any time regarding future processing in accordance to Art. 7 GDPR. Further adjustments may be possible within the settings of your third-party account.

7 Google Integrations

7.1 Google PSE

7.1.1 Scope of processing personal data

Within the CoSpace website, the "Google Programmable Search Engine" (Google PSE) is used as the central search service. The integrated search service enables a full-text search for content from the official and globally accessible Internet offering.

Data processing for the European Economic Area is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The following data is collected and stored until it is automatically deleted:

  • System language
  • Location

The following data is processed within our own servers:

  • IP-Adress
  • Search term

For further information on Google's privacy policy, please refer to the following link: https://www.google.de/intl/de/policies/privacy/

7.1.2 Legal basis for processing personal data

The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. a) GDPR. This means that this function is not activated automatically, but requires your explicit consent by activating it in the settings.

7.1.3 Purpose of data processing

The processing of this data serves the purpose of searching for images within the CoSpace via the integrated web search and processing them further using drag and drop.

7.1.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been fulfilled and there are no legal, official or contractual retention periods to prevent deletion.

7.1.5 Right of objection and erasure

You can object to the processing of your data at any time. If you have any questions about data protection or wish to exercise your rights, please contact our data protection officer. Further information about Google can be found at the following link:  https://developers.google.com/custom-search/docs/overview

7.2 Google Classroom

7.2.1 Scope of processing personal data

In our continuous effort to improve the user experience and simplify the use of our services, we have introduced an integration with Google Classroom. This integration allows teachers to create and manage "CoSpaces assignments" through their Google Classroom classes.

7.2.2 Legal basis for processing personal data

The processing of this data takes place on the basis of Art. 6 para. 1 sentence 1 lit. a) GDPR. We would like to emphasize that the protection and security of our users' personal data is of the utmost importance. When using the Google Classroom integration, no personal data of students or teachers is collected or shared without their explicit consent.

7.2.3 Purpose of data processing

To use this feature, the admin of the license plan must enable the Google Classroom integration under the license plan settings first. Once enabled, teachers that are a part of the same license plan will be able to access Google Classroom features to manage their class assignments efficiently.

7.2.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been fulfilled and there are no legal, official or contractual retention periods to prevent deletion.

7.2.5 Right of objection and erasure

8 Forum

8.1 Description and scope of data processing

We run a forum. Users can leave comments in the forum. These posts can also be commented on by third-party users. If the user publishes a comment in our Forum, we store and publish, in addition to the comment content itself, following data:

  • Time stamp of your log-in
  • Username

A transfer of the data to third parties does not take place, unless the affected person has given his/her consent.

8.2 Legal basis of data processing

This data processing is legally based on our legitimate interest (Art 6 para. 1 s.1 lit. f) GDPR) in enabling our users to participate in an active and fair community.

All data that you disclose in the context of the commenting function are given voluntarily, so that the storage of this data is based on the legal basis of Art. 6 para. 1 s. 1 lit. a) GDPR.

8.3 Purpose of data processing

The collection of data is intended to ensure the stability and usability of this website and the forum. Also, it is necessary to prevent misuse of the commenting function. In addition, comments enable our users to share their questions and experiences.

8.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

8.5  Right to objection and erasure

As far as our data processing is based on our legitimate interest, you have the possibility of objecting to data processing (see Art. 21 GDPR and “Your rights”). In the event of a disagreement, please provide us with the reasons why we should not process your personal data as we have done. We will then examine the situation and either discontinue or adjust the data processing or will tell you based on which reasons we have to continue this processing.

As far as the data processing is based on your consent, you can prevent it by not agreeing with them. You also have the option to withdraw your consent at any time (see Art. 7 GDPR and “Your rights”). A withdrawal only applies to any processing that takes place after it has been pronounced. This can be done by telephone, mail, email or any other means. In case we delete your account, the comment content will remain visible for all visitors, but your account information will be anonymized and is no longer retrievable. All other data will be deleted.

9 Online Purchase

9.1 Description and scope of data processing

When you shop in our App, we will process your first name and surname, address and email address to complete the purchase agreement and the delivery agreement with you.

9.2 Legal basis for data processing

The legal basis for this data processing is Art. 6 para. 1 s.1 lit. b) GDPR. We are processing your data for the fulfilment of purchase contracts and supply agreements.

9.3 Purpose of data processing

We process your data to close the contract, to handle the payment, for billing, to ensure on-time delivery and to inform you about that delivery.

We provide your data to our contracted processors and service providers, so that they can process the delivery and, if necessary, communicate with you to announce and coordinate the delivery of your ordered goods.

9.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

9.5 Right to objection and erasure

The data processing is necessary in order to be able to process your purchase contract, which is why it cannot be waived. There is therefore no option to object.

9.6 Stripe

9.6.1 Description and scope of data processing

We offer Stripe as a payment service. With Stripe, you can use payment information stored in your Stripe account to make purchases quickly and securely. To use the payment service through Stripe, prior registration is required. The data processing is carried out by:  Stripe Payments Europe Ltd (subsidiary of Stripe Inc., 510 Townsend Street, San Francisco, CA 94103, USA).

Data processing by Stripe is carried out only for bookings that require online payments. The information collected by Stripe includes:

  • Payment method
  • Payment method information (e.g. credit or debit card number or bank account details)
  • Purchase amount
  • Date of purchase

Different payment methods may require the collection of different categories of data. The payment method information Stripe collects depends on the payment method you choose. When you complete a transaction, Stripe may also receive:

  • Name
  • Email address
  • Billing or shipping address
  • and in some cases your transaction history to authenticate you

For more information, please see Stripe's privacy policy: https://stripe.com/en-lu/privacy

9.6.2 Legal basis for data processing

Our legal basis is based on Art. 6 para. 1 s. 1 lit. b) GDPR.

9.6.3 Purpose of data processing

The transmission of the data is necessary to prevent any misuse. We inform you that Stripe may transmit the personal data to credit agencies. This is because Stripe reserves the right to check your identity and creditworthiness.

9.6.4 Duration of storage

We will only store your data for as long as is necessary to process your payment and invoice you. If you are a Stripe user, Stripe will retain your personal data for as long as the services are provided to you. The data will then be deleted unless there are regulatory, contractual or legal retention obligations that prevent deletion.

9.6.5 Right to objection and erasure

The data processing is mandatory in order to be able to process your payment via Stripe, which is why it cannot be dispensed with if you have chosen this payment method. There is therefore no possibility to opt out.

10 Service providers from third countries

In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR).

Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR.

Consent: In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.

11 Your rights

You have the following rights with respect to the personal data concerning you:

11.1 Right to withdraw a given consent (Art. 7 GDPR)

If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.

11.2 Right of access (Art. 15 GDPR)

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

  • the purpose of processing;
  • the categories of personal data concerned;
  • the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations;
  • where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
  • all available information on the source of your personal data;
  • the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.

11.3 Right to rectification and erasure (Art. 16, 17 GDPR)

You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.

You may also request the erasure of your personal data if any of the following applies to you:

  • the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;
  • you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
  • the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.

Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

These rights shall not apply to the extent that processing is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • for the establishment, exercise or defence of legal claims.

11.4 Right to restriction of processing (Art. 18 GDPR)

You shall have the right to obtain from us restriction of processing where one of the following applies:

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  • you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.

Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.

11.5 Right to information (Art. 19 GDPR)

If you have asserted to us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.

You also have the right to know which recipients have received your personal data.

11.6 Right to data portability (Art. 20 GDPR)

You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where

  • the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and
  • the processing is carried out by automated means.

In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.

11.7 Right to object (Art. 21 GDPR)

Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.

11.8 Right to lodge a complaint with supervisory authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.

12 How you perceive these rights

To exercise these rights, please contact our data protection officer:

Kemal Webersohn from Webersohn & Scholtz GmbH

delightex@ws-datenschutz.de

or by mail:

WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

13 Subject to change

We reserve the right to change this privacy policy in compliance with legal requirements. In the case that personal data will be used in any manner inconsistent to the terms initially provided, we will inform you in a timely manner, allowing you to make a choice before such changes are enforced.

April 2024

Last updated: February 2024

Data privacy statement - CoSpaces website

Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. Our services have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our website, what happens with these data and how you may object to data usage.

1 General information on data processing

1.1 Person Responsible (Controller)

Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:

Delightex GmbH​
Address:​
 Christoph-Rapparini-Bogen 25, 80369 Munich, Germany
Email:​
info@cospaces.io
Homepage:
cospaces.io

1.2 Name and address of the Data Security Officer

The data protection officer is:
Kemal Webersohn of WS Datenschutz GmbH

If you have questions about data protection, you can contact WS Datenschutz GmbH at the following email address: delightex@ws-datenschutz.de

WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

webersohnundscholtz.de

1.3 Protection of your data

We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.

If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (data processing agreement) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons. Our App is SSL/TLS encrypted, as can be seen by the https:// at the start of our URL.

1.4 Erasure of personal data

We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

2 Use of data on this website and in log files

2.1 Scope of processing personal data

When visiting our website, the web servers, hosted by Webflow, temporarily store every access in a log file. The following data is collected and stored until automated erasure:

  • IP-address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Transmitted amount of data
  • Message if the retrieval was successful
  • Detection data of the browser and operating system used

We or our partners may process additional data occasionally. You will find information about this below.

2.2 Legal basis for processing personal data

The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our website accessible for you.

2.3 Purpose of data processing

The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.

2.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been fulfilled and there are no legal, official or contractual retention periods to prevent deletion.

2.5 Right of objection and erasure

The collection of the data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. If you have any questions about data protection or would like to exercise your rights, please contact our data protection officer or Webflow at the following email address: privacy@webflow.com

2.6 Hosting Provider Webflow

We use the services of Webflow as a hosting provider. The data processing is carried out by: Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA.Webflow is a tool for creating and hosting websites. Webflow stores cookies or other recognition technologies that are necessary for the display of the page, to provide certain website functions and to ensure security (necessary cookies).You can find more information on the data protection of the service provider here: https://webflow.com/legal/eu-privacy-policy

3 Use of cookies

3.1 Description and scope of data processing

Our website uses cookies. This means that when using the website, cookies are stored on your computer. Cookies are small text files which are assigned to the browser you are using and which are stored on your hard drive. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. They are used to analyze the use of our website in anonymized or pseudonymized form and to enable a personalized user experience on this website. The following data may be transmitted:

  • Your last session ID (encrypted)
  • Your IP address (anonymized)
  • Your cookie settings
  • Timestamp of your accepted or declined consent

Upon entering our website, a cookie banner informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website.

3.2 Legal basis for data processing

The legal basis for the processing of data by cookies, which do not only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. a) GDPR.

The legal basis for the processing of data for cookies, which serve only the functionality of this website, is Art. 6 para. 1 s. 1 lit. f) GDPR.

3.3 Purpose of data processing

Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability.

The data processing takes place to make a statistical evaluation of our website possible.

3.4 Duration of storage

This website uses the following types of cookies. The extend and function of each are being explained below:

  • Transient cookies (see a)
  • Persistent cookies (see b)

a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.

b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.

3.5 Right to objection and erasure

You have the possibility to revoke your consent to the data processing by means of cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.

4 Contact

4.1 Description and scope of data processing

Via our website it is possible to contact us via contact form. This will require different data to answer the request, which will be automatically saved for processing. The following data is required to process your request:

  • E-mail address
  • First name
  • Last name
  • Country
  • Detection data of the browser and operating system used

Furthermore, you can enter the following data optionally:

  • Information about the platform for which the contact is made
  • Information about the license plan in use
  • Information about your user role as a student or teacher
  • Personal message
  • Uploaded files

Your data will not be passed on to third parties, unless you have given your consent.

4.2 Legal basis for data processing

The legal basis depends on Art. 6 para. 1 s. 1 lit. b) GDPR.

4.3 Purpose of data processing

The processing of personal data from the input form is used solely handling the contact request.

4.4 Duration of storage

The data will be deleted as soon as we answer your request. There might occur rare cases when legal or contractual retention periods interfere with the erasure of your personal data. In this case your data will be deleted after these periods.

4.5 Right to objection and erasure

The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.

4.6 HelpScout

4.6.1 Description and scope of data processing

Our system emails are being sent by “HelpScout“, an email service provider. The personal data is being processed by: Help Scout PBC, 1000 City hall Plaza, Boston, MA 02108, USA.

Help Scout processes our and your email address, name, age, sex, gender, family status, address, education level, IP-address, location, customer satisfaction, profession, employment status, usage data and image recordings.

We trust in the reliability and the IT and data security of Helpscout. We have signed a data processing agreement with Help Scout. In this agreement Help Scout commits to protect the data of our users, to process this data according to its regulations and to not share with unauthorized third parties. You can view the privacy policy of Help Scout here: https://www.helpscout.com/company/legal/privacy/

4.6.2 Legal basis for data processing

This data processing is legally based on Art. 6 para. 1 s. 1 lit. b) GDPR. We send these emails to confirm your registration and to facilitate the verification of your registration within the same media and in a timely manner.

4.6.3 Purpose of data processing

We use Help Scout as a processor to ensure an efficient management of our system emails.

4.6.4 Duration of storage

Help Scout only stores the data for as long as it is necessary for the processing purpose. After that, the data will only be processed anonymously.

4.6.5 Right to object and erasure

The data processing is necessary in order to maintain full functionality of registering on our website. Therefore, objecting is  not possible.

5 Blog

5.1 Medium

Our blog is hosted by the online publishing platform Medium. The Platform is operated by A Medium Corporation located at 799 Market St FL 5 San Francisco, CA 94103 United States.

Users can leave comments on the blog. These posts can also be commented on by third-party users. If, at the time of visiting our blog, the user is logged in on Medium, Medium will process, in addition to the comment content itself, the following account data:

  • Your name, display name, username
  • Your photos and avatar image
  • Your activity Information
  • Your device and Usage Information

5.1.1 Legal basis of data processing

All data that you disclose in the context of the commenting function are given voluntarily, so that the storage of this data is based on the legal basis of Art. 6 para. 1 s. 1 lit. a) GDPR.

5.1.2 Purpose of data processing

We use the Medium to promote our blog and our company. We also want to give you the opportunity to interact with other Medium users.

5.1.3 Duration of storage

Medium stores your data only for as long as necessary to carry out the purposes for which they originally collected it and for legitimate business purposes, including to meet their legal, regulatory, or other compliance obligations.

5.1.4 Right to objection and erasure

You have the right at any time to revoke your consent to the publication of a comment and to object to the processing of your personal data by medium. To do so, please contact Medium at privacy@medium.com

6 Social media links

We have integrated social media platforms into our services, which may result in the social media provider receiving data from you. If you click on the social media link, the website of the respective social media provider is loaded. By loading the website of the respective social media provider via our services, the respective reference data is transmitted to the respective social media provider. The social media provider thereby receives the information that you have visited us.

Note on data processing to the United States:

If you click on a social media link, data about you may be processed by the respective provider in the United States. According to the European Court of Justice, the data protection standard in the United States is not adequate and there is a risk that your data will be processed by the U.S. authorities for control and monitoring purposes, possibly also without any legal remedy. Provided that you do not click on the links of the social media providers, no data transfer takes place.

Further information on data processing by the social media providers can be found here:

Meta:https://de-de.facebook.com/help/pages/insights

https://de-de.facebook.com/about/privacy

https://de-de.facebook.com/full_data_use_policy

Twitter: https://twitter.com/privacy?lang=de

YouTube: https://www.google.de/intl/de/policies/privacy/

7 Forum

7.1 Description and scope of data processing

We run a forum. Users can leave comments in the forum. These posts can also be commented on by third-party users. If the user publishes a comment in our Forum, we store and publish, in addition to the comment content itself, following data:

  • Time stamp of your log-in
  • Username

A transfer of the data to third parties does not take place, unless the affected person has given his/her consent.

7.2 Legal basis of data processing

This data processing is legally based on our legitimate interest (Art 6 para. 1 s.1 lit. f) GDPR) in enabling our users to participate in an active and fair community.

All data that you disclose in the context of the commenting function are given voluntarily, so that the storage of this data is based on the legal basis of Art. 6 para. 1 s. 1 lit. a) GDPR.

7.3 Purpose of data processing

The collection of data is intended to ensure the stability and usability of this website and the forum. Also, it is necessary to prevent misuse of the commenting function. In addition, comments enable our users to share their questions and experiences.

7.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

7.5  Right to objection and erasure

As far as our data processing is based on our legitimate interest, you have the possibility of objecting to data processing (see Art. 21 GDPR and “Your rights”). In the event of a disagreement, please provide us with the reasons why we should not process your personal data as we have done. We will then examine the situation and either discontinue or adjust the data processing or will tell you based on which reasons we have to continue this processing.

As far as the data processing is based on your consent, you can prevent it by not agreeing with them. You also have the option to withdraw your consent at any time (see Art. 7 GDPR and “Your rights”). A withdrawal only applies to any processing that takes place after it has been pronounced. This can be done by telephone, mail, email or any other means. In case we delete your account, the comment content will remain visible for all visitors, but your account information will be anonymized and is no longer retrievable. All other data will be deleted.

8 Tracking and analytics

For the continuous improvement of our website we use the following tracking and analytics tools. Below you can find information on which personal data is processed in each case and how you can reach the respective service providers:

8.1 Google Analytics

8.1.1 Description and scope of data processing

Our website uses Google Analytics. This is a service for analyzing access to websites of Google Inc. ("Google") and allows us to improve our website.  Data processing for the European Economic Area and for Switzerland is carried out by:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Cookies enable us to analyze your use of our website. The information collected by a cookie are:

  • IP address
  • Access time
  • Access Duration

The information is transmitted to a Google server in the USA and stored there. The evaluation of your activities on our website is transmitted to us in the form of reports. Google may pass on the collected information to third parties, if required by law or if third parties process this data on behalf of Google. The Google tracking codes of our Internet offer use the function "_anonymizeIp ()", thus IP addresses are processed only shortened, in order to exclude a possible direct personal link to you. Under https://www.google.de/intl/de/policies/ as well as under https://www.google.com/analytics/terms/de.html you can find out more about the terms of use and privacy policy of Google Analytics.

8.1.2 Legal basis of data processing

The legal basis is your given consent, Art. 6 para 1 s. 1 lit. a) GDPR.

8.1.3 Purpose of data processing

By processing the data, we can analyze how our website is used, so we can improve it for our users.

8.1.4 Duration of storage

The data will be deleted 50 months after your last website visit.

8.1.5 Right to objection and erasure

You can prevent the installation of cookies by Google Analytics in your browser settings. In this case, however, it may happen that you cannot fully use all features of our website. Also, through browsers extensions e.g. https://tools.google.com/dlpage/gaoptout?hl=de Google Analytics can be disabled and controlled.

8.2 Google Tag Manager

8.2.1 Description and scope of data processing

Google Tag Manager is a solution that allows us to manage web site tags through one interface (including Google Analytics and other Google marketing services on our website). The tag manager itself (which implements the tags) does not process users' personal data. Regarding the processing of users' personal data, reference is made to the details of the Google services. Google Tag Manager usage policies can be viewed here: https://www.google.com/intl/de/tagmanager/use-policy.html

9 Other tools of third-party providers

9.1 Google ReCaptcha

9.1.1 Description and scope of data processing

We use Google reCAPTCHA to protect us from excessive spam regarding the usage of our contact form. This program is designed to ensure that the inquirer is a human and not an automated program. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google automatically records the IP address, the access location and the time of access. In addition, the behavior of the website visitor is analyzed on the basis of various characteristics (e.g. time spent by the visitor on the website, mouse movements made, cookies stored in the browser history). This analysis by Google begins automatically as soon as you call up a page that uses Google reCAPTCHA, if you have previously consented to the use of Google reCAPTCHA. Further information on the handling of personal data can be found in the Google privacy policy https://www.google.de/intl/de/policies/privacy, at https://policies.google.com/technologies/partner-sites and at https://www.google.com/recaptcha.

9.1.2 Legal basis of data processing

Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.

9.1.3 Purpose of data processing

Through Google reCAPTCHA, we ensure that there are natural persons with potential interest behind the requests. By limiting the number of inquiries in this way, we can respond to individual requests more quickly and more efficiently, and at the same time secure our website against automatically distributed malware.

9.1.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

9.1.5 Right to objection and erasure

You have the option to withdraw your consent to data processing at any time, see Art. 7 GDPR. A withdrawal takes effect from the time at which it is expressed. The withdrawal will be effective for the future. For this purpose, please contact our data protection officer.

10 Service providers from third countries

In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR).

Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. For more information, see: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR.

Consent: In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.

11 Your rights

You have the following rights with respect to the personal data concerning you:

11.1 Right to withdraw a given consent (Art. 7 GDPR)

If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.

11.2 Right of access (Art. 15 GDPR)

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

  • the purpose of processing;
  • the categories of personal data concerned;
  • the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations;
  • where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
  • all available information on the source of your personal data;
  • the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.

11.3 Right to rectification and erasure (Art. 16, 17 GDPR)

You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.

You may also request the erasure of your personal data if any of the following applies to you:

  • the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;
  • you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
  • the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.

Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

These rights shall not apply to the extent that processing is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • for the establishment, exercise or defence of legal claims.

11.4 Right to restriction of processing (Art. 18 GDPR)

You shall have the right to obtain from us restriction of processing where one of the following applies:

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  • you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.

Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.

11.5 Right to information (Art. 19 GDPR)

If you have asserted to us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.

You also have the right to know which recipients have received your personal data.

11.6 Right to data portability (Art. 20 GDPR)

You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where

  • the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and
  • the processing is carried out by automated means.

In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.

11.7 Right to object (Art. 21 GDPR)

Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.

11.8 Right to lodge a complaint with supervisory authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.

12 How you perceive these rights

To exercise these rights, please contact our data protection officer:

Kemal Webersohn from Webersohn & Scholtz GmbH
delightex@ws-datenschutz.de

or by mail:

WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

13 Subject to change

We reserve the right to change this privacy policy in compliance with legal requirements.

February 2024