Privacy Policy / Datenschutzerklärung

Last Update / Letzte Änderung: 06.01.2021 (added LinkedIn Insight Tag), previous last update: 29.11.2019

We are delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Expath Training & Consulting GmbH. The use of the Internet pages of the Expath Training & Consulting GmbH is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Expath Training & Consulting GmbH. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Expath Training & Consulting GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone or by visiting one of our offices.

1. Definitions

The data protection declaration of the Expath Training & Consulting GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a)    Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c)    Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d)    Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e)    Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f)     Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g)    Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h)    Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i)      Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j)      Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k)    Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Expath Training & Consulting GmbH

Jansastr. 9

12045 Berlin

Deutschland

Phone: 030 880 63 605

Email: info (at) expath.de

Website: www.expath.de

3. Name and Address of the person responsible for Data Protection

The person responsible for data protection at Expath Training & Consulting GmbH is:

Stephan Brenner

Expath Training & Consulting GmbH

Jansastr. 9

12045 Berlin

Deutschland

Phone: 03088063605

Email: stephan.brenner (at) expath.de

Website: www.expath.de

Any data subject may, at any time, contact him directly with all questions and suggestions concerning data protection.

4. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

5. Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact any employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Expath Training & Consulting GmbH, he or she may at any time contact any employee of the controller. An employee of the Expath Training & Consulting GmbH shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of the Expath Training & Consulting GmbH will arrange the necessary measures in individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Expath Training & Consulting GmbH, he or she may at any time contact an employee of the controller. An employee of the Expath Training & Consulting GmbH will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the Expath Training & Consulting GmbH.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Expath Training & Consulting GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If the Expath Training & Consulting GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Expath Training & Consulting GmbH to the processing for direct marketing purposes, the Expath Training & Consulting GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Expath Training & Consulting GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact any employee of the Expath Training & Consulting GmbH. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the Expath Training & Consulting GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of the Expath Training & Consulting GmbH or another employee of the controller.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact any employee of the Expath Training & Consulting GmbH.

6. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

7. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

8. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

9. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

10. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

11. Clear-text descriptions of data processing per data subject

  • Website Visitors
  • Online Workshop Purchasers
  • Applicants
  • Internal Language students
  • external language students
  • relocation clients
  • coaching clients
  • corporate contacts
  • Partners & service providers

Definition of Data Subject

Casual Browsers: A person who views page(s) of the Expath website without subscribing to or using any other services.

Newsletter Subscribers: A person who signs up to the Expath newsletter via a form on the Expath website.

Online Placement Test-takers: A person who uses the Expath website to take Expath’s Online Placement Test.

Contact Form Submitters: A person who submits a contact or feedback form in order to contact Expath’s staff.

1) Overview of Data Protection

As visitor to Expath’s website, certain information about you will be collected and stored when perusing our services. This information, according to the General Data Protection Regulation, or GDPR, is called “personal data”. Personal data is essentially any data related to you or that could personally identify you in any way, directly or indirectly. At Expath, we take the protection of your data seriously by following GDPR regulations. In general, Expath collects and processes personal data exclusively to fulfill legal and contractual obligations. The following will provide you with a clear overview of what data we collect from you, what we do with that data, and what rights you have under GDPR regulations.

2) Data Controllers

A “data controller” or “data processor” is a person or company who collects and processes personal data. Because we collect your information, Expath is a data controller and data processor. Expath’s information is as follows:

Expath Training & Consulting GmbH (Expath)

Jansastraße 9

12045 Berlin, Germany

Email: info@expath.de

Phone: +49 (0) 30 880 63 605

Under GDPR, Expath is required to appoint a designated Data Protection Officer (DPO) that you may contact for further questions about Expath’s protection of your data. Expath’s DPO and his contact information is listed below:

Stephan Brenner

Torstraße 117

10119 Berlin, Germany

Email: stephan.brenner (at) expath.de

Phone: +49(0) 30 437 73 678

3) Data Collection

Based on the services you use on our website, Expath may collect and store the following information from you:

  • Hardware Use
  • Website Visitors: Date and time of visit to website
  • Newsletter Subscribers: Date and time of sign up and cancellation
  • Online Test Takers: Date and time of test taken
  • Contact Form Submitters: Date and time of feedback form submission
  • Electronic ID Data
  • IP address
  • Cookies
  • Personal Identification Data
  • Newsletter Subscribers: Name and email
  • Online Test Takers: Name and email (if provided), test score, employer
  • Contact Form Submitters: Name, title, email address, phone number, employer
  • Inferred Data*
  • Hobbies, Interests, and Leisure Activities

*[During your interactions with Expath, you may give us information that implies other information. We call this “inferred data”. Specific information is not stored.]

4) Data Usage

Expath uses, or processes, your personal data in a few ways. There are several processes that are directly relevant to you as a visitor to our website. These processes are listed below, with descriptions of what they entail.

  • Information Technology
  • These processes include website optimization and maintenance of online security, including cloud-based software.
  • Marketing/Sales
  • These processes include marketing Expath’s services to potential customers and clients and to manage sales activities.
  • Quality Control
  • These processes include evaluation and assurance of the quality and performance of Expath employees and freelancers, and legal obligations.

Specific information about you is required for specific processes. The relevant data used in each process is listed below:

  • Information Technology
  • Hardware Use
  • Electronic ID Data
  • Marketing/Sales
  • Personal Identification Data
  • Hobbies, Interests, and Leisure Activities
  • Quality Control (Contact Form Submitters)
  • Hardware Use
  • Personal Identification Data

5) Retention & Storage

All personal data stored by Expath is kept for 10 years and then deleted, according to our legal obligations. Your data is securely stored by Expath in local storage sites and in different sub-processors. A sub-processor is any business, contractor, or organization that assists us, the data controller or main processor, in processing your personal data.

The storage sites and sub-processors we use to collect and process your data are listed below, with descriptions and their security characteristics:

  • Expath Email Server (Hetzner)
  • Overview: An email server created by Hetzner, an Internet hosting company and data center operator based in Germany.
  • Security Characteristics:
  • Our website’s data backups are stored on a physical server in Germany, called Hetzner (Hetzner Online, GmbH Industriestr. 25 91710 Gunzenhausen, Germany).
  • All data generated automatically by visiting/using Expath’s website is stored through Hetzner’s web service as a backup. This information usually is stored in a cookie, or a small text files that your internet browser stores on your computer. Information stored via Hetzner from cookies includes your name, contact information, and electronic data (e.g. your computer’s IP address). Hetzner uses this information to regulate internal processes, personalize browsing to your preferences, and for marketing purposes.
  • Hetzner may forward your data to their service partners to optimize their services. When required by law, Hetzner will transmit your data to relevant government authorities.
  • Expath is not involved in any of these processes. If you object to Hetzner’s use of your data, please contact them directly.
  • Further information on the purpose and scope of data collection and processing by Hetzner Online can be found in Hetzner Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Expath Website (Hetzner)
  • Overview: A website server created by Hetzner, an Internet hosting company and data center operator based in Germany.
  • Security Characteristics: See above (#2).
  • Google Analytics
  • Overview: A web analytics service operated by Google that tracks and reports website traffic. Expath uses this to track and improve site performance and user experience.
  • Security Characteristics:
  • Expath uses Google Analytics, a web analytics service. It is operated by Google (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
  • Google Analytics works through the use of cookies. Cookies are text files that are stored on your computer which allow an analysis of your use of our website. This information is usually transmitted to a Google server in the USA and stored there. Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO.
  • Under instructions from Expath, Google will use this information to analyze your use of our website, compile reports on activities on the website, and to provide us with further services relating to use of the platform and internet usage. The IP address transferred by your browser when Google Analytics is used is not connected to any other information Google may possess about you.
  • We have activated the IP anonymization feature on this website for Google Analytics. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
  • We do not share Google Analytics data without the customer’s authorization (including authorization via settings in the product user interface), or as otherwise expressly permitted under the terms of their Google Analytics agreement, except in limited circumstances when required by law.
  • You can prevent cookies from being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of our website. You can also prevent the data generated by cookies about your use of the website (including your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available here.
  • Further information on the purpose and scope of data collection and processing by Google can be found in Google’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Mailchimp
  • Overview: A marketing automation platform and email marketing service based in the United States.
  • Security Characteristics:
  • To deliver our email newsletter to you, Expath uses Mailchimp (The Rocket Science Group LLC Mailchimp, 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308 USA).
  • Mailchimp is an online platform that we use to create, send, and manage emails. In order to send out emails on behalf of a company, Mailchimp collects your personal data. The information Mailchimp collects includes your name, email, email activity, and newsletter emails sent to you. Furthermore, Mailchimp uses cookies, which transmit data about your computer’s IP address, browser, etc.
  • Mailchimp uses this information in order for companies such as Expath to properly use its services (e.g. sending out our newsletter). Mailchimp also uses your personal data to measure their Email Campaign’s performance, improve site features for customers, evaluate your use of their website, compile reports on website activity for operators, and to provide other services related to website activity and internet usage.
  • Mailchimp may transfer your data to third parties when required by law to do so, or when third parties process information on behalf of Mailchimp. Expath is not responsible for these transmissions of data, nor do we have an interest in these processes.
  • Mailchimp has the endorsement of TRUSTe's Privacy Seal, which means their privacy policy complies with TRUSTe’s requirements including transparency and accountability regarding the collection and use of your personal data TRUSTe is an independent third party that operates a globally-recognized privacy trustmark.
  • Further information on the purpose and scope of data collection and processing by Mailchimp can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Quiz and Survey Master (WordPress Plugin)
  • Overview: A customizable quiz creation and maintenance WordPress plugin.
  • Security Characteristics:
  • In order to offer you our German online placement test, Expath uses the WordPress plugin Quiz and Survey Master.
  • Quiz and Survey Master is a customizable quiz creation and maintenance plugin. When interacting with our placement test, you are interacting with Quiz and Survey Master.
  • Quiz and Survey Master collects information you voluntarily submit to Expath via our placement test. This information may include your name, address, contact information (email and phone number), company name, and title. Quiz and Survey Master uses this information to verify your identity, understand demographics of users, measure traffic patterns, regulate internal business activities, modify and maintain their services, and for marketing purposes.
  • Quiz and Survey Master may share your information to third parties in certain situations. These parties include public forms, their service providers, and/or legal authorities. Your data is shared to these parties for internal management, business purposes, and legal requirements.
  • Expath is not involved in the processing or transferring of your data by Quiz and Survey master. If you object to any of the processes mentioned above, please contact them directly.
  • Further information on the purpose and scope of data collection and processing by Quiz and Survey Master can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Social Media Plugins (Facebook & Twitter & Linkedin)
  • Overview: Facebook is an online American-based social media and networking service used by Expath as a marketing and communication tool. Twitter is an American online news and social networking service where users post and interact with messages, or “tweets”.
  • Security Characteristics:
  • Expath currently uses the following social media plug-ins: Facebook (Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA) and Twitter (Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA).
  • In order to protect your data, we use a “two-click” solution. This means that when you visit our site, none of your personal data is initially passed on to Facebook or Twitter. You can identify the provider of the plug-in by the mark on the box above its initial letter or logo. We offer you the option of communicating directly with the plug-in provider via the button. Your personal data and information regarding your activity on our website is only transmitted to the plug-in provider if you click on the corresponding button.
  • If you choose to click on the Facebook or Twitter button, your IP address, date and time of access, time zone, page accessed on Expath’s website, HTTP status code, browser, and browser’s language will be transferred to Facebook or Twitter. This information is transferred regardless or not if you have an account through the use of a small pixel on the webpage with the plug-in. Facebook will also note which webpage you used on our website to access their website. If you are already logged into your Facebook or Twitter account, this data will be connected to this account. You can avoid the assignment of information to your Facebook and/or Twitter by logging out of your corresponding account before clicking the plug-in button on our website.
  • Facebook
  • Your IP address is made anonymous immediately after it has been collected. By activating the plug-in, personal data is transferred from you to Facebook and eventually stored there (for US providers). The plug-in provider collects the data in particular via cookies. It is possible to delete all cookies via the security settings of your browser before clicking on the icon of the respective social media plug-in.
  • Facebook or Twitter may save the data collected about you as user profiles and use these profiles for the purposes of advertising, market research and/or demand-oriented design of its website. In particular, such analysis may be used to display demand-oriented advertising and to inform other users of the social network about your activities on our website in connection with the plug-in’s offer. You have the right to object to the creation of these user profiles. In order to do so, you must contact Facebook or Twitter to exercise this right.
  • Through these plug-ins, Expath intends to offer you the possibility to interact with social networks and other users. The legal basis for the use of the plug-ins is Art. 6 para. 1 S. 1 lit. f GDPR, whereby our legitimate interest is the provision of an interactive and user-friendly web offer.
  • Expath has no influence on the data collected or processed by Facebook and Twitter. If you object to the collection or processing of your data by Facebook or Twitter, please contact them directly.
  • Further information on the purpose and scope of data collection and processing by Facebook and Twitter can be found in Facebook's Privacy Policy and Twitter’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.

    • LinkedIn Insight Tag

    This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

    Data processing by LinkedIn Insight tag

    We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.

    LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.

    The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn's privacy policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.

    Legal basis

    The use of LinkedIn Insight is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in effective advertising measures, including social media. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; the consent can be revoked at any time.

    Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa und https://www.linkedin.com/legal/l/eu-sccs.

    Objection to the use of LinkedIn Insight Tag

    You can object to LinkedIn's analysis of user behavior and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

    In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

    Execution of a contract data processing agreement

    We have entered into a contract data processing agreement with LinkedIn.

  • Vimeo
  • Overview: An ad-free open video platform based in the US.
  • Security Characteristics:
  • We have included Vimeo videos in our online workshops, which are stored at https://vimeo.com/de/ and can be played directly from our website.
  • Vimeo will be informed if you have accessed the corresponding subpage of our website. In addition, electronic information such as your IP address will be transmitted. This is independent of whether Vimeo provides a user account through which you are logged in or whether no user account exists. Vimeo stores your data as a user profile and uses it, possibly for the purposes of advertising, market research and/or the design of its website according to demand. In particular (even for users who are not logged in), such an evaluation can lead to demand-oriented advertising and – depending on the offer of the provider – to information of 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 Vimeo to exercise this right.
  • Further information on the purpose and scope of data collection and processing by Vimeo can be found in Vimeo’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Visual Form Builder (WordPress Plugin)
  • Overview: A WordPress plugin used to create contact forms for a website.
  • Security Characteristics:
  • In order to provide contact forms and feedback forms on our website, Expath uses the WordPress plugin Visual Form Builder (M2 Development, LLC, 507 Amherst Avenue Terrace Park, OH 45174, USA).
  • Visual Form Builder is a plugin that allows Expath to build and manage forms for our website. When filling out a contact form or a feedback form on our website, Expath requests that you include certain personal data, including your name and contact information. This information is then sent to our email server (Hetzner) from Visual Form Builder’s platform.
  • Visual Form Builder does not collect information about you, nor does it transmit any information to third parties. We use Visual Form Builder as a platform to collect your information and never transmit this information to employees at Visual Form Builder.
  • Further information on the purpose and scope of data collection and processing by Visual Form Builder can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Wordfence Security
  • Overview: A WordPress plugin, firewall, and malware scanner that protects websites located on a WordPress domain from a variety of digital threats.
  • Security Characteristics: In the interest of protecting our website, Expath uses a WordPress plugin called Wordfence Security (Defiant, Inc., 800 5th Ave Street 4100, Seattle, WA 98104, USA). Wordfence is a firewall and malware scanner that protects websites located on a WordPress domain from a variety of digital threats. It is essential to have some form of firewall when you have a commercial website – Expath.de is constantly under attack by malicious bots and hackers. In order to distinguish malicious visitors from friendly ones, Wordfence uses and collects cookies. These cookies contain your IP address. Wordfence uses this information to distinguish which users have access privileges and also ensure a website’s firewall is set up accordingly.To help you understand which cookies the Wordfence sets to collect your data, we have provided the guide below. Wordfence currently sets three cookies.
  • wfwaf-authcookie-(hash) What it does: This cookie is used to perform a capability check of the current user before WordPress has been loaded. Who gets this cookie: This is only set for users that are able to log into WordPress. How this cookie helps: This cookie allows the firewall to detect logged in users and allow them increased access. It also allows Wordfence to detect non-logged in users and restrict their access to secure areas. The cookie also lets the firewall know what level of access a visitor has to help the firewall make smart decisions about who to allow and who to block.
  • wf_loginalerted_(hash) What it does: This cookie is used to notify Wordfence admin when an administrator logs in from a new device or location. Who gets this cookie: This is only set for administrators. How this cookie helps: This cookie helps site owners know whether there has been an admin login from a new device or location.
  • wfCBLBypass What it does: Wordfence offers a feature for a site visitor to bypass country blocking by accessing a hidden URL. This cookie helps track who should be allowed to bypass country blocking. Who gets this cookie: When a hidden URL is visited, this cookie is set to verify the user can access the site from a country restricted through country blocking. This will be set for anyone who knows the URL that allows bypass of standard country blocking. This cookie is not set for anyone who does not know the hidden URL to bypass country blocking. How this cookie helps: This cookie gives site owners a way to allow certain users from blocked countries, even though their country has been blocked.
  • Expath has entered into a “data processing agreement” with Wordfence. This agreement essentially states that Wordfence will protect your data and will not share it with any third parties. For more information about this processing agreement, click here.
  • Further information on the purpose and scope of data collection and processing by Wordfence Security can be found in Wordfence’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.

  • WordPress
  • Overview: A free and open-source content management system.
  • Security Characteristics:
  • In order to operate a functional website, Expath uses the website hosting software WordPress (WordPress Foundation, Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA).
  • WordPress collects non-personally-identifying information that web browsers and servers typically make available. This information includes your browser type, language preferences, referring site, and date and time of visit to our website. Additionally, WordPress collects IP addresses stored via a cookie in your computer’s hard drive. This collection happens automatically upon visit to our website, and Expath is not involved in this process.
  • WordPress uses your information for site maintenance, in registering for a WordPress account, attending WordPress events, receiving newsletters, or participating in WordPress services in any way. WordPress also uses your information for marketing purposes, but you can opt out of this by contacting WordPress.
  • WordPress discloses your information to third parties on a need-to-know basis in order to provide services to you or WordPress. These parties must agree not to disclose your information to others.
  • Further information on the purpose and scope of data collection and processing by WordPress can be found in their  Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Yoast
  • Overview: A search engine optimization WordPress plugin.
  • Security Characteristics:
  • Expath uses Yoast (Yoast BV, Don Emanuelstraat 3 6602 GX Wijchen, the Netherlands), a search engine optimization WordPress plugin, in order to advertise our website and services on Google.
  • Yoast uses web analytics tools to analyze how users use our website. These tools use cookies, which collect internet log information and visitor behavior in an anonymous form. Such information typically will include your IP address. Your IP address and other information stored in cookies will then be transmitted to Google by Yoast, which is used to evaluate visitor use of our website and to compile statistical reports on website activity. This helps Yoast provide recommendations for search optimization and regulate internal functions of their own website. Yoast never allows any third parties access to your personally identifiable information.
  • Expath is not involved in Yoast’s methods of processing your data. If you object to Yoast using your data for any reason, please contact Yoast directly.
  • Further information on the purpose and scope of data collection and processing by Yoast can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.

Depending on what it’s being used for, different types of data will be stored in different sub-processors. The following list shows where each category of your personal data is stored:

  • Hardware Use
  • Website Visitors: Google Analytics, Wordfence Security (WordPress Plugin)
  • Newsletter Subscribers: Mailchimp
  • Online Test Takers: Quiz and Survey Master (WordPress Plugin)
  • Contact Form Submitters: Expath Email Server (Hetzner), Visual Form Builder (WordPress Plugin)
  • Electronic ID Data
  • Google Analytics, Quiz and Survey Master (WordPress Plugin), Social Media Plugins, Vimeo, Visual Form Builder (WordPress Plugin), Wordfence Security (WordPress Plugin), Yoast
  • Personal Identification Data
  • Newsletter Subscribers: Mailchimp
  • Online Test Takers: Quiz and Survey Master (WordPress Plugin), WordPress
  • Contact Form Submitters: Expath Email Server (Hetzner), Visual Form Builder (WordPress Plugin)

6) Third Parties

In order to perform certain processes, we may transmit some of your personal data to third parties. A third party is a person, organization, or public authority that isn’t you or Expath. The third parties we send your information, the data they receive, and the reason for transmission are listed below:

  • Google Analytics
  • Personal Data Transmitted: Electronic ID Data
  • Purpose of Transmission: Website Optimization
  • Wordfence
  • Personal Data Transmitted: Electronic ID Data
  • Purpose of Transmission: Website Optimization and Security

Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.

Expath collects, processes, and transmits your personal data, with your consent, exclusively for the following legally acceptable purposes: 1) to fulfill legal obligations, 2) to protect your vital interests, and 3) to perform services you request by contract. These purposes are outlined under Art. 6 (1) (b) of the DSGVO. For more information, please visit https://gdpr-info.eu/art-6-gdpr/.

This Privacy Policy has been partly generated by the Privacy Policy Generator of the German Association for Data Protection that was developed in cooperation with RC GmbH, which sells used IT and the filesharing Lawyers from WBS-LAW.

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