Privacy Policy / Datenschutzerklärung

Last Update / Letzte Änderung: 16.08.2019

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

- Visa/Work Permit Seekers: A person who receives help from Expath regarding visas or work permits in Germany.

- Relocation Package Purchasers: A person who receives Expath’s full relocation package services.

  • Overview of Data Protection
  • As a relocation client at Expath, certain information about you will be collected and stored over the course of your relationship with us. 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.
  • 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@expath.de
  • Phone: +49(0) 30 437 73 678
  • Data Collection
  • Expath collects and stores the following information from you on a need-to-know basis:
  • Employment Information
  • Current employer
  • Work responsibilities
  • Wage, salary, income, and wealth
  • Working hours
  • Termination of employment
  • Resume Information
  • Professional Career
  • Professional Qualifications
  • Professional Experience
  • Educational Career
  • Property Information
  • Information about your rental property for apartment searches
  • Data on Presence and Absence
  • Your availability
  • Orders
  • What services you purchased from Expath
  • Date ordered
  • Images/Photographs
  • Passport pictures
  • Biometric Identification (Signatures)
  • Passports, work permits, etc.
  • Data About Family Members (for family relocation)
  • Data about minors
  • Marital status
  • Hardware Use
  • Date and time of emails
  • Immigration Data
  • Visas
  • Work permits
  • Financial Identification
  • Bank users: IBAN, bank name, bank account number, BIC code
  • Credit Card users: last four digits of card, type of card, card expiration
  • PayPal users: PayPal email address
  • Use of Media and Means of Communication
  • Email address
  • Phone number
  • Public Identification Data
  • Passport number, Sozialversicherungsnummer
  • Personal Details
  • Passport Information: Age, sex, date of birth, place of birth, nationality
  • Personal Identification Data
  • Name, title
  • Email address, phone number
  • Address
  • Travel Plans
  • Date of arrival in Germany
  • Incidental Data*
  • Data about sexuality, Hobbies, interests, and leisure activities, Marital chronology, Ethnic origin/Race, Physical traits

*[During your correspondence with Expath, especially during the visa/work permit application process, you may provide us information we don’t require. We call this “incidental data”. This information typically can’t be separated from other required information you provide us. We do not use this information for any processes listed below.]

  • 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 relocation client. These processes are listed below, with descriptions of what they entail.
  • Accounting/Finance
  • These processes include invoice creation and management, bookkeeping, and fulfillment of legal financial obligations.
  • Relocation Client Booking
  • These processes include relocation services management, scheduling, and communication with relocation clients.
  • Quality Control
  • These processes include evaluation and assurance of the quality and performance of all Expath employees and freelancers.
  • Specific information about you is required for specific processes. The relevant data used in each process is listed below:
  • Accounting/Finance Processes
  • Orders
  • Financial Identification
  • Personal Identification Data
  • Relocation Client Booking
  • Employment Information
  • Resume Information
  • Property Information
  • Data about Presence and Absence
  • Orders
  • Images/Photographs
  • Biometric Identification (Signatures)
  • Data About Family Members (for family relocation)
  • Hardware Use
  • Immigration Data
  • Use of Media and Means of Communication
  • Public Identification Data
  • Personal Details
  • Personal Identification Data
  • Travel Plans
  • Quality Control
  • Use of Media and Means of Communication
  • Personal Identification Data
  • 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:

  • Commerzbank
  • Overview: A universal bank with an online banking system.
  • Security Characteristics:
  • In order to make and receive payments via bank, Expath uses Commerzbank (Commerzbank AG, Kaiserplatz 60261 Frankfurt am Main, Germany).
  • When making a transaction via bank with Expath, Commerzbank collects a few types of personal data. This data includes your name, address, contact data, place of birth, nationality, date of transaction, legitimization data (ID cards), and authentication data (signatures). Contractual data, like payment orders, advertising data, and information about your financial status may also be stored by Commerzbank.
  • Commerzbank uses this data for a variety of reasons. Most of these reasons relate to internal management and analysis of service functionality. Other reasons include the prevention and investigation of criminal acts, advertising or marketing (which can be limited by you if you object to this), and legal accountability.
  • Commerzbank may transfer your information to third parties. These third parties must comply with GDPR regulations, as well as contractual and statutory obligations. Data is transferred to Commerzbank’s service providers and agents in categories such as banking services, IT services, logistics, printing services, telecommunication, collection of receivables, consultation, and sales and marketing.
  • You can object to any of these processes by contacting Commerzbank directly. Expath does not take part in the data processing mentioning above, and does not control what Commerzbank does with your data.
  • Further information on the purpose and scope of data collection and processing by Commerzbank can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • 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’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Google Calendar
  • Overview: A time management and scheduling calendar service developed by Google.
  • Security Characteristics:
  • Expath uses Google Calendar (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to keep track of both language school and relocation services scheduling.
  • Google Calendar is a time-management and scheduling calendar service developed by Google which allows users to create and edit events. Expath uses Google Calendar internally to schedule appointments, coaching sessions, and list client availability. Information about you typically included in our private Google Calendar includes your name, times available, and a summary of services you requested from us.
  • Expath shares information stored in Google Calendar with all Expath employees and coaches. We do not share your data with any third parties from Google Calendar. Expath also does not use Google Calendar to integrate your calendar with ours for scheduling purposes.
  • Data uploaded to Google Calendar is encrypted. Google does not have access to unencrypted data, and uses all encrypted data for internal maintenance and advertising purposes. Google does not share any data available on Google Calendar with third parties.
  • Further information on the purpose and scope of data collection and processing by Google can be found in the Google’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Google Drive
  • Overview: A file storage and synchronization service developed by Google. This is used by Expath as an alternate file server, especially in cases where files need to be shared or co-edited externally.
  • Security Characteristics:
  • In order to keep track of your contact information (including names, emails, phone numbers, etc.) Expath uses Google Drive (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
  • Google Drive a file storage and synchronization service developed by Google. Google Drive allows users to store files on their servers, synchronize files across devices, and share files.
  • Expath creates files in Google Drive with your contact information. This information is never transferred to third parties, and is accessible only by certain Expath employees.
  • Google encrypts all files created in Google Drive. This means that no one but us can view what’s inside these files. Google uses AES-256, a secure encryption algorithm without any currently feasible attacks, to encrypt files. Furthermore, Google splits data within each file into chunks, and then encrypts each chunk of data with a specific data key. Only after this process takes place is data stored by Google.
  • Expath is not involved in the storage or processing of files stored in Google Drive by Google.
  • Further information on the purpose and scope of data collection and processing by Google can be found in the Google’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Lexoffice
  • Overview: An online accounting software based in Germany. This is used by Expath for all invoicing and financial reporting.
  • Security Characteristics:
  • In order to manage invoices for clients, employees, and freelancers, Expath uses Lexoffice (Haufe Service Center GmbH & Co. KG, Munzinger Strasse 9 79111 Freiburg, Germany).
  • Expath uses Lexoffice to store invoices and all payments made to and from Expath. We use Lexoffice to fulfill our legal obligation to maintain a double-entry bookkeeping system. Double book-keeping essentially means we cross-reference our online transaction information with created invoices coming to or from Expath.
  • A variety of personal data is stored by Expath in Lexoffice. Personal data is all stored in payment information you send or give to us, as well as in invoices. This information is never sent to Lexoffice or other third parties. Lexoffice never has access to data we store on its server.
  • If you visit Lexoffice’s website for any reason, your electronic information (e.g. information found in digital cookies such as your IP address and browser used) may be stored. Expath is not associated with Lexoffice’s website, nor are we involved in their methods of data processing.
  • Further information on the purpose and scope of data collection and processing by Lexoffice can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Local physical hard-drive
  • Overview: Non-removable, encrypted hardware storage devices used for local file storage. These usually are located in our local computers.
  • Security Characteristics:
  • All physical hard drives exist within computers running Windows 10 Professional and have been encrypted using BitLocker software. Thus, data cannot be accessed if hard drives are removed. Accessing hard drives requires individual user login data for the respective computer.
  • NitroPro & Smallpdf
  • Overview: NitroPro is a software that allows users to convert digital file types into PDF format. Smallpdf is a software that allows users to compress digital files.
  • Security Characteristics:
  • When compiling your documents to send to local immigration authorities (such as Berlin’s BIS), Expath uses NitroPro (Nitro Software, Inc. of 150 Spear St STE 1500, San Francisco CA 94105) and Smallpdf (Smallpdf GmbH, Zurich).
  • NitroPro is a software that allows Expath to convert other digital file types into PDF format. This conversion is necessary for us to submit your documents to local immigration offices. NitroPro allows users to upload and manipulate documents to their server, but does not change the content of these documents themselves. NitroPro is able to see the contents of these documents. Data may be used to recommend services to us to improve our experience with NitroPro.
  • Further information on the purpose and scope of data collection and processing by NitroPro can be found in NitroPro’s Privacy Policy. There you will also find more information about your rights as well as options to protect your privacy.
  • Smallpdf is a software that allows Expath to compress digital files. This process is also necessary for us to submit your documents to local immigration offices. Smallpdf allows users to upload many documents at the same time to compress them into one file, but Smallpdf does not change the content of these documents. Smallpdf deletes all files uploaded to their server for purposes of compression after one hour, meaning any documents uploaded to Smallpdf are inaccessible to Smallpdf.
  • Further information on the purpose and scope of data collection and processing by Hetzner Online can be found in Smallpdf’s Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • PayPal
  • Overview: A US-based online payment system that supports money transfers and is an electronic alternative to checks and money orders.
  • Security Characteristics:
  • Expath accepts payments via PayPal (PayPal Holdings, Inc., S.à.r.l & Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg).
  • PayPal is an online payment processor that supports online money transfers and serves as an alternative to physical checks and money orders. Expath uses PayPal so you can pay for our online services, such as our online workshop, languages, and coaching sessions.
  • If you select payment via PayPal, the payment data (credit card number, bank information, etc.) you provide will be supplied to PayPal based on Art. 6 (1) (a) (Consent) and Art. 6 (1) (b) DSGVO (processing for contract purposes). Other information PayPal collects include any information you give them if you choose to register for an account (name, contact information, etc.) or any information you give them if you check out as a guest. PayPal also collects electronic information about your computer, including your IP address, browser used to purchase our services, etc. PayPal collects this data for a variety of reasons, including marketing purposes, to manage internal business needs, to prevent fraud, and to comply with legal obligations.
  • PayPal may share your data with select third parties. These parties include other corporations associated with PayPal, companies that perform services for PayPal, with other financial institutions, with legal entities when necessary, and with other users, merchants or provider involved in your transaction. This data is shared for fraud prevention, internal management, protection of personal interests, and is always shared only with your consent. You have the option to revoke your consent at any time with future effect. This action does not affect the processing of data previously collected.
  • Expath is not involved in PayPal’s actions regarding your personal data.
  • Further information on the purpose and scope of data collection and processing by PayPal can be found in PayPal's Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Physical Copies
  • Overview: A paper copy of a document stored in a binder in one of Expath’s offices.
  • Security Characteristics:
  • All binders are kept in a locked cabinet or closet in our office, which is itself locked when not staffed.
  • ReloTalent
  • Overview: A cloud-based relocation management software that focuses on company and employee relocation.
  • Security Characteristics:
  • Expath uses ReloTalent to manage relocation clients’ requests and needs, as well as store a variety of sensitive documents (ReloTalent Pte. Ltd 14 Rue d'Uzès 75002 Paris, France).
  • ReloTalent is a relocation management software that focuses on company employee relocation. When using ReloTalent’s website, your IP address and other information stored in cookies will be recorded by ReloTalent. ReloTalent stores certain personal data for marketing, legal, and internal management purposes. This information is not collected by Expath, and is processed solely by ReloTalent.
  • Expath requests that you upload a variety of sensitive documents to ReloTalent. This information is password-protected, meaning no one except you, your coach, your company, and us can see this information. This information not used by ReloTalent for other purposes not listed above. Personal data can be deleted at any point on ReloTalent’s website.
  • Expath is not involved in the processing of your data by ReloTalent. If you object to the collection or processing of your data by ReloTalent, please contact them directly.
  • Further information on the purpose and scope of data collection and processing by ReloTalent can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Skype
  • Overview: A telecommunications application that specializes in providing video chat and voice calls between computers, tablets, mobile devices, etc. via the Internet. Skype is primarily used by coaches and coaching clients.
  • Security Characteristics:
  • In order to communicate with remote coaches, clients, and corporate clients face-to-face, Expath uses Skype (Skype Technologies S.A.R.L., Microsoft Corp., 23-29 Rives de Clausen L-2165 Luxembourg City, Luxembourg).
  • Skype collects various data when you use their services. This data includes your name, contact data (email, phone number, etc.), credentials, demographic data you provide, interactions through Skype, and images you upload to their platform. Skype uses this information for marketing purposes, customer support, content personalization, safety, communication purposes, and for legal compliance.
  • Expath is not involved in any of these processing methods. If you object to the collection or use of your data by Skype, please contact them directly.
  • Further information on the purpose and scope of data collection and processing by Sofortüberweisung can be found in Microsoft's Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Sofortüberweisung/Klarna
  • Overview: A bank payment service that allows cashless payment of products and services through the Internet as an intermediary for online banking transfers.
  • Security Characteristics:
  • Expath uses Sofortüberweisung (SOFORT GmbH, Fußbergstraße 1, 82131 Gauting, Germany), a bank payment service that allows cashless payment of products and services through the Internet. Sofortüberweisung uses a technical procedure by which you immediately receive a payment confirmation upon using their services. This enables us to deliver services to the customer (you) immediately after ordering.
  • If you choose to pay for a service through a bank transfer, your data will be transmitted to Sofortüberweisung. By selecting this payment option, you agree to the transmission of personal data required for payment processing.
  • The information sent to Sofortüberweisung initially includes your bank account PIN and TAN number. Sofortüberweisung then carries out a transfer to Expath after technical verification of your account status and retrieval of additional data to check the account assignment. You are then automatically informed of the execution of the financial transaction.
  • Personal data exchanged with Sofortüberweisung includes your first name, last name, address, email address, IP address, telephone number, mobile phone number, and data necessary for payment processing. The transmission of this data is necessary for payment processing and fraud prevention. The personal data exchanged between Sofortüberweisung and Expath is then transmitted by Sofortüberweisung to economic credit agencies. This transmission is intended for reference purposes and creditworthiness checks. Sofortüberweisung also provides personal data to affiliated companies, service providers, and subcontractors as far as is necessary for the fulfillment of contractual obligations or data in order to be processed.
  • You are able to revoke consent to the handling of personal data at any time from Sofortüberweisung. A revocation shall not have any effect on your personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
  • 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 Sofortüberweisung can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Stripe
  • Overview: A credit card processing software that allows individuals and businesses to make and receive payments over the Internet.
  • Security Characteristics:
  • Expath uses Stripe (Stripe, Inc. 510 Townsend Street Francisco, CA 94103, USA), a credit card processor, to help you conveniently pay for a variety of our services.
  • If you choose to pay for a service with your credit card, your data will be transmitted to Stripe. By selecting this payment option, you agree to the transmission of personal data required for payment processing.
  • The information sent to Sofortüberweisung initially includes your (or the cardholder’s) name, card number, card expiration date, CVC code, and billing address. Stripe then processes the transaction and you are then automatically informed that the financial transaction has been completed. This information is received and stored directly by Stripe, and is not stored by us during the financial transaction.
  • Further information on the purpose and scope of data collection and processing by Stripe can be found in their Privacy Policy. There you will find more information about your rights as well as options to protect your privacy.
  • Tresorit
  • Overview: An online cloud storage service based in Switzerland and Hungary emphasizing enhanced security and data encryption. This is Expath’s primary data server.
  • Security Characteristics:
  • Expath uses Tresorit (Tresorit AG Minervastrasse 3, 8032 Zurich) to store a variety of sensitive and non-sensitive documents including but not limited to relocation documents, invoices, and client contact information.
  • Tresorit is an online cloud storage program that focuses on privacy and security. Tresorit uses end-to-end encrypted storage, which means Tresorit will never have access to documents uploaded into its server. Other security features Tresorit boasts include encryption at rest and in transit, zero-knowledge authentication, 2-step verification, and HIPAA compliance.
  • Further information on the purpose and scope of data collection and processing by Stripe can be found in their 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.
  • WhatsApp
  • Overview: A freeware, cross-platform messaging service owned by Facebook that allows users to send and receive text and voice messages.
  • Security Characteristics:
  • In order to communicate with clients, partners, and freelancers, Expath uses WhatsApp (WhatsApp Inc., Mountain View, California, USA).
  • WhatsApp is a freeware, cross-platform messaging service owned by Facebook that allows users to send text and voice messages. When you interact with Expath via WhatsApp, WhatsApp collects and stores certain types of data from you. This information includes your WhatsApp account information (your profile name, phone number, etc.), your connections, usage and log information, device location information, device and connection information, and cookie information (e.g. IP address). This information is kept for service maintenance, safety and security, and commercial messaging. WhatsApp does not store or retain your messages, or messages sent to you by Expath.
  • WhatsApp may share some of your data with third-parties. These parties include WhatsApp’s service providers and other Facebook products, if you use them. Expath is not involved in the collection or transmission of your data by WhatsApp.
  • 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.

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:

  • Employment Information
  • Expath Email Server (Hetzner), Local Physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Resume Information
  • Expath Email Server (Hetzner), Google Calendar, Local physical hard-drive, Tresorit
  • Property Information
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Data about Presence and Absence
  • Google Calendar, Google Drive, Expath Email Server (Hetzner)
  • Orders
  • Expath Email Server (Hetzner), Lexoffice, Local physical hard-drive, Physical copy, ReloTalent, Tresorit (up to June 2019)
  • Images/Photographs
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Biometric Identification (Signatures)
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Data About Family Members (for family relocation)
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Hardware Use
  • Expath Email Server (Hetzner)
  • Immigration Data
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Financial Identification
  • All: Expath Email Server (Hetzner)
  • Bank Users: Commerzbank, Sofortüberweisung/Klarna
  • Credit Card Users: Stripe
  • PayPal Users: PayPal
  • Use of Media and Means of Communication
  • Expath Email Server (Hetzner), Google Drive, Local physical hard-drive, ReloTalent, Skype, WhatsApp
  • Public Identification Data
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Personal Details
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Smallpdf, Tresorit
  • Personal Identification Data
  • Expath Email Server (Hetzner), Local physical hard-drive, NitroPro, Physical copy, ReloTalent, Skype, Smallpdf, Tresorit, WhatsApp
  • Travel Plans
  • Expath Email Server (Hetzner)
  • 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:
  • Business Immigration Services (BIS)
  • Personal Data Transmitted: Employment Information, Images/Photographs, Biometric Identification, Data About Family Members (if applicable), Immigration Data, Public Identification Data, Personal Details, Personal Identification Data, Travel Plans
  • Purpose of Transmission: Complete Legal Obligations of Visa and/or Work Permit Applications
  • Auditors
  • Personal Data Transmitted: All data
  • Purpose of Transmission: Fulfill Legal Obligations
  • Your Freelance Coach
  • Personal Data Transmitted: Employment Information, Resume Information, Property Information (if applicable), Data about Presence and Absence, Orders, Images/Photographs, Biometric Identification, Data About Family Members (if applicable), Hardware use, Immigration Data, Use of Media and Means of Communication, Public Identification Data, Personal Details, Personal Identification Data, Travel Plans
  • Purpose of Transmission: Fulfillment of Relocation Services and Communication with Coach
 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.

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.