Data Protection

Data Protection

Privacy Policy in accordance with Art. 13 GDPR – Fulfilment of information obligations

Controller

The data controller in accordance with Art. 4 (7) EU General Data Protection Regulation (GDPR) is

Aspire Beteiligungs GmbH

Geiselbergstraße 15-19, 1110 Vienna, Austria

Tel: +43 1 718 86 86 – 0

Email: office@aspire-education.com

The company has appointed a data protection officer. He can be reached at datenschutz-aspire@meineberater.at

2 The companies data processing

We process the data that data subjects provide to us through their own statements, for example in the context of an enquiry by e-mail, for the purpose of initiating and concluding a contract or a business relationship.

2.1 Data subjects

We process the following data from interested parties: Company, name of contact person and professional contact data as well as address data.

We process the following data from suppliers and business partners: Company, title and names of contact persons, professional address data and contact data, bank details, contract data.

2.2 Passing on data

Personal data will only be passed on to third parties if this is necessary for the purpose of processing and fulfilling the contract or if it is required by law.

2.3 Data retention

The data will be deleted by us as soon as storage is no longer necessary or legal retention periods have expired. If the basis of the processing is consent, we restrict the processing or delete the data upon revocation of the consent – unless there are legal provisions to the contrary.

2.4 Contact by e-mail

When you contact us by e-mail, the data you provide will be stored by us on the basis of your consent in order to answer your questions. We delete the data accruing in this context after the processing is no longer necessary or restrict the processing if there are legal retention periods.

2.5 Legal basis

The below points are the legal basis of data processing:

  • Initiation and fulfilment of a contract in accordance with Art. 6 para. 1 lit. b GDPR.
  • Legal obligations in accordance with Art. 6 para. 1 lit. c GDPR, (for example, legally prescribed storage and documentation obligations).
  • Legitimate interests of our company in accordance with Art. 6 para. 1 lit. f GDPR (for example statistical evaluations).
  • 6 para. 1 lit. a GDPR when obtaining consent (for example when processing image data or for advertising purposes).

3 Data processing via our website

3.1 Contact

If you have asked us to contact you via our web form or you have sent us a message, then we store the data from you that is required to contact you. This is your name, your email address and other data that you provide to us in the contact field. The data will be deleted by us as soon as storage is no longer necessary or you object to the processing.

Legal basis: Art. 6 para. 1 lit. a GDPR

3.2 Applicants

If you send us your application documents, we will process your personal data contained therein as well as your CV and references for the purpose of personnel selection and filling the position. In the event of a rejection, we delete your documents 7 months after sending the rejection to you.

Legal basis: Art. 6 para. 1 lit. b GDPR

If you consent to be kept on file with us for the purpose of contacting you at a later date, we will approach you with a separate request for the transmission of a consent. If you explicitly give us this consent, we will store your consent. If there is no further opportunity to fill a vacancy with us within one year, we will delete all your applicant data one year after you have sent us your consent.

Legal basis: Art 6 para 1 lit a GDPR

4 Data processing when visiting our website

4.1 Informational use of the website

When you use our website for information purposes only, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect at most the data that is technically necessary for us to display our website to you and to ensure its stability and security:

  • IP address
  • Date and time of the request
  • Time zone difference from Coordinated Universal Time (UTC)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Website from which the request came
  • browser
  • Operating system and its interface
  • Language and version of the browser software.

Legal basis: Art. 6 para. 1 lit. f GDPR

4.2 Cookies

In addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive in relation to the browser you are using and which provide the party setting the cookie (in this case us) with certain information. Cookies cannot execute programs or transmit viruses to your computer.

The cookie enables you to be recognised when you visit the website without having to re-enter data that you have already entered previously.

The information contained in the cookies is used, for example, to determine whether you are logged in or what data you have already entered, or to recognise you as a user when a connection is established between our web server and your browser. Cookies are automatically accepted by most web browsers.

By using our websites, you agree to the use of these cookies, insofar as cookies are accepted according to your browser settings.

4.2.1 Transient cookies

Transient cookies are automatically deleted when you close the browser. These include, in particular, session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the joint session. This enables your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close the browser.

4.2.2 Persistent cookies

Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

4.2.3 Third-party cookies

These come from providers other than the website operator. They can be used, for example, to collect information for advertising, custom content and web statistics.

4.2.4 Browsers

Most browsers are set by default to accept all cookies. You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of our website may be limited.

You can remove cookies stored on your PC yourself at any time by deleting the temporary internet files.

Legal basis: Art. 6 para. 1 lit. f GDPR (in the case of technical cookies), Art. 6 para. 1 lit. a GDPR (for all other cookies).

4.3 Data processing in the USA

It cannot be ruled out that personal data will be transmitted to the USA when visiting our website. If this is the case, we point this out at a separate point in this privacy policy.

The GDPR requires so-called appropriate safeguards according to Art. 46 GDPR for a data transfer to a third country or to an international organisation. Such guarantees do not exist for the USA.

Possible risks that cannot currently be excluded for you as a data subject in connection with the aforementioned information are in particular:

  • Your personal data may be shared with other third parties (e.g.: US authorities) by the respective service provider beyond the actual purpose of fulfilling the order.
  • You may not be able to assert or enforce your rights of access against the respective service provider in the long term.
  • There may be a higher probability of incorrect data processing because the technical organisational measures for the protection of personal data do not fully comply with the requirements of the GDPR in terms of quantity and quality.

With your consent to the processing of (advertising and marketing) cookies, you explicitly consent to the transfer of data to the USA. You can remove cookies stored on your PC yourself at any time by deleting the temporary internet files.

Legal basis: Art. 6 para. 1 lit. a GDPR

5 Social media presence

We operate social media sites such as LinkedIn, Xing, YouTube, Facebook, etc.. When visiting our social media presence, personal data, including the IP address from the respective provider, is processed and cookies are used for data collection. Please refer to the privacy policy of the respective service to find out exactly what information is transmitted. There you will also find information about contact options as well as for various settings.

We focus on comprehensive customer satisfaction and use these services primarily to be able to get in touch or to communicate with you. Furthermore, we see it as an additional possibility to our other existing information offers.

In the case of services with a US connection, the data collected is usually sent to a server in the USA and stored there. We have no influence or control over the type and scope of the data processed by these services, the type of processing and use or the transfer of this data to third parties. For options to restrict the processing of this data in the respective settings of these services, please refer to the detailed descriptions of the privacy policies of the respective providers.

Furthermore, we point out that you use the respective services and their functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. sharing, commenting or rating).

The providers of the social media services have provided us with corresponding agreements on the joint responsibility of data processing. The use of social media is based on our legitimate, operational interest.

Legal basis: Art. 6 para. 1 lit. f GDPR.

6 Data processing for services provided by Google

We have signed a contract with Google Ireland Limited (“Google”), a company incorporated and operated under the laws of Ireland (registration number: 368047) with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. Nevertheless, it may happen that data is transmitted from Europe to the USA, over which we as a company have no influence.

Through the use of this service, a transfer of personal data to the USA takes place or cannot be ruled out! – For more details, see 4.3 of this declaration.

Legal basis: Art 6 para 1 lit a GDPR

6.1 Google Analytics

This website uses the function “Activation of IP anonymisation” (i.e. Google Analytics has been extended by the code “gat._anonymizeIp();” to ensure anonymised collection of IP addresses (so-called IP masking)). This means that your IP address is shortened beforehand by Google within member states of the European Union 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.

According to Google, Google will use the information obtained to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to website and internet use. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. However, 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 prevent the storage of cookies by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of the website to their full extent. Furthermore, you can prevent the collection of the data generated by the cookie and related to your use of the websites (including your anonymised IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).

For more information on the terms of use and data protection, please visit https://marketingplatform.google.com/about/analytics/terms/us/ or https://support.google.com/analytics/answer/6004245?hl=en.

6.2 Google Doubleclick

The website uses the online marketing tool DoubleClick. To help AdWords customers and publishers serve and manage ads on the web, the Google advertising network and certain Google services may be used. DoubleClick uses cookies to serve ads that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to record which ads are shown in which browser and can thus prevent them from being shown more than once. In addition, DoubleClick can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later calls up the advertiser’s website with the same browser and buys something there. According to Google, DoubleClick cookies do not contain any personal information. Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of DoubleClick, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is still possible for the provider to obtain and store your IP address.

6.3 Google Fonts

We use Google Fonts. Google Fonts are used without authentication and no cookies are sent to the Google Fonts API. If you have an account with Google, none of your Google account data will be transmitted to Google during the use of Google Fonts. Google only records the use of CSS and the fonts used and stores this data securely. You can find out more about these and other issues at https://developers.google.com/fonts/faq.

You can find out what data is collected by Google and what it is used for at https://policies.google.com/privacy?hl=en.

6.4 Google Gstatic

Gstatic is a domain used by Google to load static content into another domain name in order to reduce bandwidth usage and increase network performance for end users.

6.5 Google Maps

On this website we use the services of Google Maps. This allows us to display interactive maps directly on the website and enables you to use the map function conveniently. By visiting the website, Google receives the information that you have called up the corresponding sub-page of our website. In addition, the data already mentioned under the point “Informational use of the website” will be transmitted. This occurs regardless of whether Google provides a user account via which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want your data to be associated with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or designing its website in line with requirements. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.

For more information on the purpose and scope of data collection and processing by the plug-in provider, please refer to the provider’s privacy policy. There you will also find further information on your rights in this regard and setting options for protecting your privacy: https://policies.google.com/privacy?hl=en-US

6.6 Google reCaptcha

We use the Google service reCaptcha to determine whether a human or a computer makes a certain entry in our contact or newsletter form. Google uses the following data to check whether you are a human or a computer: IP address of the terminal device used, the website you visit with us on which the captcha is embedded, the date and duration of the visit, the recognition data of the browser and operating system type used, Google account if you are logged in to Google, mouse movements on the reCaptcha areas and tasks that require you to identify images.

6.7 Google Tag Manager

We use so-called Google Tag Managers to recognise your user behaviour. The Google Tag Manager is a solution that marketers can use to manage website tags via an interface. The tool itself processes the following personal data: IP address of the user. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data.  The Google Tag Manager can set cookies, at least in the preview and debug mode of the administrator, but also outside of it. If a deactivation has been made at domain or cookie level, this remains in place for all tracking tags implemented with Google Tag Manager.

More detailed information is available here: https://support.google.com/tagmanager/?hl=en#topic=3441530

7 Data processing when using server log files

In order to optimise this website in terms of system performance, user-friendliness and the provision of useful information about our services, the website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This includes the internet protocol address (IP address) of the requesting computer (including mobile devices), browser and language setting, operating system, referrer URL, your internet service provider and date/time.

This data is not merged with personal data sources. We reserve the right to check this data retrospectively if we become aware of concrete indications of unlawful use and to pass the data on to the law enforcement authorities if there has been a hacking attack. The data will not be passed on to third parties beyond this.

Legal basis: Art. 6 para. 1 lit. f GDPR

8 Data processing when using Usercentrics

This is a consent management service. Usercentrics GmbH is used on the website as an order processor for the purpose of consent management.

The data controller is Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany. Email address of the data protection officer of Usercentrics GmbH: datenschutz@usercentrics.com

You can find the company’s privacy policy here: https://usercentrics.com/privacy-policy/

Cookies are only stored for the duration of the browser session.

Legal basis: Art. 6 para. 1 lit. f GDPR.

9 Data processing when using YouTube

We operate a YouTube channel and have integrated YouTube videos into our website, which are stored on http://www.YouTube.com. When you watch one of our YouTube videos, a connection to YouTube servers is established. This tells YouTube which pages you are visiting. The operating company of YouTube is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Through the use of this service, a transfer of personal data to the USA takes place or cannot be ruled out! – For more details, see 4.3 of this declaration.

Further information on data protection at “YouTube” can be found in the provider’s privacy policy at: https://www.google.de/intl/en/policies/privacy/.

Legal basis: Art 6 para 1 lit a GDPR

10 Your rights

You have the following rights in relation to personal data relating to you:

  • Right of access, right to rectification and erasure
  • Right to restriction of processing
  • Right to object to processing
  • Right to data portability
  • Right to complain to the supervisory authority, which is the Austrian Data Protection Authority

Barichgasse 40 – 42, 1030 Vienna, telephone: +43 1 52 152-0

E-mail: dsb@dsb.gv.at

If you believe that we have violated Austrian or European data protection law in the processing of your data and have thereby infringed your rights, please contact us so that we can clarify any issues you may have.

For this purpose, please direct your enquiries and concerns by e-mail to office@aspire-education.com or contact us using the contact details provided.

11 Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time. Changes to this privacy policy will be published by us on this page. Please refer to the current version of our privacy policy in this regard.