Privacy Statement

Valid as of 27. March 2018

Preamble

We would like to inform you in this privacy statement about the type, scope and purpose of personal data collection, processing and use upon use of the websites provided by Lecturio, “www.lecturio.de”, “www.lecturio.com”, and sub-domains like “kunde.lecturio.com” and of the services offered on such websites (e.g. apps). Lecturio is trustworthy and the protection of your personal data is very important. This is why we would like to show you in a transparent way how and why your data are being used. We would like to offer you user-friendly, good, customer oriented and secure services by storing, processing and using personal data.

Lecturio also complies with U.S. laws, including the Family Educational Rights and Privacy Act (“FERPA”), where applicable, which provide privacy protections for personal data.

§ 1 Definitions

Personal data

“personal data” means any information relating to an identified or identifiable natural person (“data subject” or “you”); 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;

Controller

“controller” means 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;

Processor

“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Third party

“third party” means 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 authorised to process personal data;

§ 2 Name and contact data of the controller

The following party is responsible within the meaning of EU-GDPR and other applicable data protection laws of the European Union and its member states:

Lecturio GmbH
Käthe-Kollwitz-Str. 1
04109 Leipzig
(“Lecturio”, “we” or “us”)

Telephone: +49 341 355 699 - 70
support@lecturio.com

§ 3 Name and contact data of the data protection officer

The data protection officer of the controller for data processing is:

Mr. Martin Reininger
Lecturio GmbH
Käthe-Kollwitz-Str. 1
04109 Leipzig
(“data protection officer”)

Any person concerned may contact the data protection officer directly at any time at the above mentioned address or via email to data-privacy@lecturio.com if he/she has any questions or suggestions regarding data protection.

§ 4 Purpose and legal basis of data processing

Lecturio operates a platform that records online courses for students and professionals in cooperation with experts and makes them available via browser and mobile apps. The services of Lecturio are generally time and location-independent. Various data relating to your member account are collected, stored, processed and used depending on the extent to which you use the services offered by us.

Collection of general data and information

Specific data transmitted by your browser when visiting our websites are stored automatically by our servers. The log files created thereby include data like your IP address, the URL and landing page, the time, type and number of requests, data volume transferred, date, time and duration of individual accesses, your browser type as well as other similar information that serve as emergency response in the case of attacks on our IT systems and as protection against license abuse.

The collection and use of the information stored in the log files only serves to correctly deliver the contents of our websites, for anonymous evaluations for statistical purposes (like analyzing the user behavior), to improve our services and to provide law enforcement authorities information necessary for prosecution in the case of cyber attacks. These data are not used to draw conclusions about a person concerned.

Data and information provided by the user

You may submit as registered user your own comments, learning notes, keywords (“tags”), reviews and other similar information within the framework of use of our services (“user contents”) which are partially visible for other users also. We reserve the right to store, process and use posts that are visible for other users in anonymous form after the deletion of the user account also, unless you ask us not to. You can find out more about this in our terms of use: https://www.lecturio.com/en/elearning/legal/termsofuse

Monitoring of learning progress

Our system collects data about your personal user behavior, such as your learning progress, viewed videos and answered quiz questions or similar activities in order to provide you with optimal support while learning. These may be viewed depending on the implementation of the administrators of your employer or your university / educational institution. Data regarding your learning progress are not passed on to unauthorized third parties under any circumstances.

Lecturer’s learning content

Learning content uploaded and created by using services provided by us – such as videos, screencasts, quiz questions, documents and similar educational content (“educational content”) – is only available to users within the same organization in which they were created or submitted and to which they have been allocated.

Business inquiries and offers

You have as business client the possibility to request service offers for your company on our website via a form. We use a service of HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland (“Hubspot”) on our website for such inquiries. We hereby manage our inquiries by using an integrated software solution. All personal data sent via such form are transferred to Hubspot for further processing by a Lecturio employee. Hubspot also stores cookies on your computer. You can find more information about stored cookies and Hubspot data protection here: https://legal.hubspot.com/de/privacy-policy

§ 5 Recipient of personal data

Additional processors and third parties are necessary for the delivery of our service. These receive, inter alia, personal data. These services and the purposes for which the data are submitted to them are listed in the following paragraphs. Apart from this, only specific employees from Lecturio have access to personal data when this is required for delivering a service.

§ 6 User account and registration

We store and use data provided by you when subscribing to our services or using our services, such as when opening a member account, for the purpose of performing the services you would like to use according to contract. These data include email address, password, name, title as well as other information (such as age, sex, final degree, etc.) that you submit when setting up a member account. If you have submitted on this occasion a high school email address also, it will be used for the sole purpose of verifying if you attend that specific school or educational institute.

Facebook Connect

We offer you the possibility to register for our service with Facebook Connect. You will be directed to the Facebook page for registration, where you can log in with your user data. Your Facebook profile will be hereby linked to our service. We automatically receive data, such as your user name and email address, from Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) by linking. We use and store these data for the purpose of registration and authentication at Lecturio. The information submitted to us will be listed in detail when you log in at Lecturio via Facebook for the first time.

We only use your name, email address, date of birth and sex from these data. This information is absolutely necessary for the conclusion of contract, so that we may be able to identify you. You can find more information about Facebook Connect and privacy settings in the privacy notice and the terms of use of Facebook.

XING

We also offer you the possibility to register with us by using the data stored in your XING account. We will hereby automatically receive information, such as your user name and email address, from XING SE, Dammtorstrasse 30, 20354 Hamburg, Germany (“XING”). We use and store these data for the purpose of registration and authentication at Lecturio. The information submitted to us will be listed in detail when you log in at Lecturio via XING for the first time.

We only use your name, email address, date of birth and sex from these data. This information is absolutely necessary for the conclusion of contract, so that we may be able to identify you. You can find more information about XING and privacy settings in the privacy notice and the terms of use of XING.

§ 7 Payment services

If you want to access fee-based services on our website, you will have to additionally submit bank, credit card or other payment processing data and your address as well as other information during the ordering process. Of course, we will handle all information submitted by you in accordance with legal requirements and within the framework of the collaboration agreed upon. Payment processing data will be forwarded to processors within the framework of the statutory provisions in order to be able to process the payment. We will not store your credit card data. The personal data provided by you and relevant for the payment processing are subject to the security and data protection regulations of the following services:

PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxemburg, Luxemburg (“PayPal”).

Braintree Inc., 222 W Merchandise Mart Plaza, Suite 800, Chicago, IL 60654, USA (“Braintree”).

Stripe Inc., 185 Berry Street, Suite 550, San Francisco, CA 94107, USA (“Stripe”).

RatePAY GmbH, Franklinstrasse 28-29, 10587 Berlin, Germany (“RatePay”).

Braintree, Stripe and PayPal are PCI DSS certified and therefore meet the most stringent requirements for safe handling and storage of credit card data.

You will find more information about the security of your personal data with regard to credit card payments on https://www.braintreepayments.com/en-de/features/data-security and https://stripe.com/de/legal. You will find more information about the security of your personal data with regard to purchases on account on https://www.ratepay.com/zusaetzliche-geschaeftsbedingungen-und-datenschutzhinweis-dach/

§ 8 Cookies

We use so-called cookies on our websites. These are small text information that is stored on your computer. Cookies enable us to speed up the navigation on our website, to adapt it to your needs and interests and to avoid the misuse of our services. Our server may thus identify your computer as soon as you connect to our website, so that you don’t have to log in every time you visit our website. We use so-called permanent cookies on our websites. These enable us to preserve and provide your personal settings or displays over a longer period (depending on each service) within the context of the service. Permanent cookies are deleted automatically after a specified duration that may be different for each cookie. You may delete the cookies at any time in the security settings of your browser. You can configure your browser settings according to your wishes and refuse to accept cookies. But please note that you may not be able to use all functions of the website in this case. Cookies that are stored by our service in your browser:

Name Storage period Purpose
lctii 2 years Institutions-ID
lctlk 2 years Login key
lctalc 2 years Auto login cookie
lctrk 2 years Visitor-ID
lssn 1 year Session cookie

§ 9 Web analytics and social plugins

Google Analytics and Google Tag Manager

This website uses Google Analytics and Google Tag Manager, a web analysis service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics and Google Tag Manager also use so-called “cookies”, text files that are stored on your computer and enable an analysis of your use of our website. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there.

We have activated IP anonymisation, so that your IP address will be previously shortened by Google within member states of the European Union or in other contractual states to the Agreement on the European Economic Area. Your full IP address will be transferred to a Google server in the USA and shortened there only in exceptional cases. Google will use this information on our behalf in order to evaluate the use of the website, to compile reports on website activities and to provide other services associated with website use and internet us on our behalf.

The IP address transmitted by your browser within the scope of Google Analytics will not be merged with other data from Google.

You may prevent the storage of cookies by setting your browser accordingly; but please note, that you may not be able to use all functions of the website to the full extent in this case. You can also prevent Google to process and collect data generated by the cookie with regard to your use of our website (incl. your IP address) by using the following link to download and install the browser plugin for deactivation: https://tools.google.com/dlpage/gaoptout

You will find more information about the date protection regulation of Google Analytics on: https://support.google.com/analytics/answer/6004245

Remarketing

We use various services in order to make the internet offer more interesting for you. This advertising function enables us to show users who have already visited our website and were interested in our offer, targeted, personalized and interest-related advertisements on other websites, such as in Google Display net. The advertisement is inserted by using cookies that help us analyze the user behavior when visiting our website and may be subsequently used for targeted product recommendations and interest-based advertising. The personal data are not stored and user profiles with personal data are also not created.

The following remarketing services are used on our website:

Google Adwords (“Google Adwords”) from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). You can object to the use of the corresponding cookies in the advertisement manager https://adssettings.google.com/authenticated?hl=en. You will find the data protection regulation of Google here: https://www.google.com/intl/policies/policies/privacy/

AdRoll, 972 Mission Street, 3rd Floor, San Francisco, CA 94103, USA (“AdRoll”). You can find the data protection regulation of AdRoll here: https://www.adroll.com/about/privacy

Criteo

Anonymised information about the surfing habits of website visitors is collected and stored on our websites by the technology of Criteo GmbH, Gewürzmühlstr. 11, 80538 Munich, Germany (“Criteo”) for marketing purposes. These data are stored in cookies on the computer of the visitor. Criteo analyzes the anonymised recorded surfing habit using an algorithm and can subsequently show targeted product recommendations as personalized advertising banners on other websites (so called publishers). In no case will these data be used to personally identify you as a visitor of our website. The collected data are used for the sole purpose of improving the offer. This information is not used otherwise or disclosed to third parties.

You can object to the completely anonymous analysis of your surfing habits on our websites by using the following link to deregister: https://www.criteo.com/privacy/

You can find more information about the used technology and the data protection from Criteo on https://www.criteo.com/privacy/.

Social plugins (Facebook, Google+ and Twitter)

So-called social plugins (“plugins”) of the social networks Facebook, Google+ and of the micro blogging service Twitter are used on our website. These services are provided by the following companies (“providers”): Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”), Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google” or “Google+”) and Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”).

You can find an overview of the plugins from Facebook and their appearance here:
https://developers.facebook.com/docs/plugins

You can find an overview of the plugins from Google and their appearance here:
https://developers.google.com/+/web/

You can find an overview of the Twitter buttons and their appearance here:
https://about.twitter.com/en_us/about/resources/buttons

Your browser will establish a direct connection with the servers of Facebook, Google or Twitter when opening a page of our advertising presence that contains such plugins. The respective provider transmits the content of the plugin directly to the browser and integrates it in the page. By integrating the plugin, the providers receive the information that your browser has opened the respective page of our advertising presence, even if you don’t have a profile or are not logged in. This information (including your IP address) is transmitted directly by your browser to a server of the respective provider in the USA and stored there.

If you are logged in on one of the services, the provider may directly associate the visit on our webpage with your profile on Facebook, Google+ or Twitter. If you interact with the plugins, for example by clicking the “Like”, “+1” or “Twitter” button, the corresponding information will also be transmitted directly to a server of the provider and stored there. The information will also be shared with your contacts on the social network or your twitter account.

You will find more information about the purpose and extent of data collection and further processing and use of the data by providers as well as your rights and settings available to protect your privacy in the data protection notice of the providers.

Data protection notice of Facebook: https://www.facebook.com/policy.php
Data protection notice of Google: https://developers.google.com/+/web/buttons-policy
Data protection notice of Twitter: https://twitter.com/en/privacy

If you don’t want Google, Facebook or Twitter to directly associate the data collected via our advertising presence with your profile in the respective service, you will have to log out from the corresponding service before visiting our webpage. You can also completely prevent loading the plugins through add-ons for your browser, such as the script blocker “NoScript” (https://noscript.net/).

Affiliate program

website uses the tracking function of the affiliate software Quality Click of the company NetSlave GmbH, Simon-Dach-Str. 12, 10245 Berlin (“Quality Click”). Quality Click uses cookies, text files that are stored on your computer. The cookies qc_1, qc_id and pid provide information about the source though which users access our website and enable us therefore to determine affiliate from which users visit our page. The cookies are valid for maximum 30 days. Personal data are not stored. So long as the cookie is valid, we, as website operators, are only able to determine via the Quality Click software that you have clicked a specific link and therefore accessed one of our internet offers. The number of clicks on these links as well as the date and time are included in the statistics. It is also counted how many users access a target page with a “conversion tag”. However, the statistics do not contain any data that would allow us to draw conclusions regarding you as a person.

You can prevent the installation of cookies by changing your browser settings accordingly.

By using this website, you agree to the processing of the data collected about you via Quality Click as described above and for the above mentioned purposes.

VWO

This website uses Visual Website Optimizer (“VWO”), a web analysis service of Wingify, 14th Floor, KLJ Tower North, Netaji Subhash Place, Pitam Pura, Delhi 110034, India (“Wingify”). VWO is used to test the user-friendliness of specific pages. Anonym measurement values regarding usage patterns are collected for this purpose. We are not able to assign these anonym measurement values – via the allocation of your IP address or by other means - to your person. In order to receive meaningful test results, so-called cookies are also used, meaning that the program uses the function of your browser intended to temporary buffer information for subsequent use. Insofar as the cookies do not expire at the end of the session, they are available for maximum 100 days (you can find further details here: https://vwo.com/knowledge/what-are-the-cookies-stored-by-vwo/). You can delete the cookies in your browser at any time. You also have the possibility to refuse to participate in tests by following the instructions from the following link: https://vwo.com/opt-out/. You can find more information about the data protection from Wingify here: https://vwo.com/privacy-policy/.

JW-Player

The player of the company LongTail Ad Solutions, Inc., 2 Park Avenue, 10th Floor, NY 10016, USA (“JW-Player”) is used on our websites to play audio and video files and to collect data, such as your IP address, browser type and operating system, while playing media files for statistical purposes, in particular for analysis of media requests. The JW-Player also stores your preferred player settings in so-called cookies, text files that are stored on your computer.

§ 10 App analytics and push messages

Mixpanel

You have the possibility to activate the option “push messages” when you use our apps via a push-capable device. We use push messages in order to help you get started by sending useful tips to your device and informing you about the latest course releases and specific content as well as occasional discount campaigns and similar content based on your learning progress. You can revoke your consent to receive messages at any time by changing your device settings. Push messages are sent via a service of Mixpanel Inc., 405 Howard Street, Floor 2, San Francisco, CA 94105, USA (“Mixpanel”).

We also us an analysis tool from Mixpanel in our apps in order to collect user data from the iOS and Android app and better understand how users interact with their apps. Mixpanel is used to retrace and improve activities within the app, such as the navigation between courses or app logouts. These non-personal data are stored on Mixpanel servers in the USA. You can find further information in the privacy statement of Mixpanel: https://mixpanel.com/privacy/.

Crashlytics

We use Crashlytics (“Crashlytics”), a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) to collect user data when users use our apps on iOS or Android. Crashlytics collects data about app use, in particular with regard to system crashes and errors. Information about the device, the installed app version as well as other information that can help us correct errors, in particular with regard to the software and hardware of the user, are used for this purpose.

You can find further information in the privacy statement of Crashlytics: https://try.crashlytics.com/terms/privacy-policy.pdf

Adjust

Our mobile apps use the usage analysis technology “adjust.io”, a service provided by adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany (“Adjust”). Adjust collects installation and event data, such as “app opened” or “account opened” when you open our app. We use this anonymised information in order to better understand how our users interact with the app and to analyze mobile ad campaigns. Adjust uses your anonymised IDFA or Android ID as well as your anonymised IP and MAC address for such analysis. It is not possible to individually identify you. You can find more information about the data protection from Adjust here: https://www.adjust.com/privacy-policy/

§ 11 Newsletter

You have the possibility to subscribe to our newsletter. The submission of your email address is necessary for this purpose. We use optivo® broadmail (“Optivo”), a service provided by Episerver GmbH, Wallstrasse 16, 10179 Berlin, Germany, to send our newsletter. We use the so-called double-opt-in process (DOI). After subscription to our newsletter, you will receive an email where you will be asked for confirmation. When registering for the newsletter, we will store your IP address and the date of registration. This storing only serves as proof in the case that a third party misuses an email address and subscribes to the newsletter without the knowledge of the party concerned.

A so-called tracking pixel is used upon opening a newsletter. The following data are stored thereby: email address, newsletter, opening date and time. The links in our newsletters contain tracking information that enables us to determine which links were of interest to you if you have clicked them. The following data are stored in Optivo via the tracking link: email address, newsletter, link, date and time.

You can revoke your approval to receive newsletters at the email address specified by you at any time for the future by sending an email to support@lecturio.com.

§ 12 Duration during which personal data are stored

The duration of personal data storage is based upon the legal storage period and the personal data are routinely deleted after the expiry of this period or immediately after termination of the membership of Lecturio or at an earlier date upon request of a person concerned, insofar as the data are not required to fulfill or initiate a contract. The following data are stored beyond termination of contract for so long as they are required for a specific purpose:

  • offer data: 1 year (after feedback from the client),
  • contract documents: 10 years,
  • IP data: 3 years (regular limitation period)
  • legal matters: 6 years
  • claims: 10 years

In order to terminate your membership, please contact our customer service by sending an email to support@lecturio.com.

§ 13 Rights of the data subject

You have as person concerned the following rights:

  • right of access by the data subject
  • right to rectification or erasure as well as restriction of data processing
  • right to object to data processing
  • right to data portability
  • right of appeal before supervisory authoritie

If you want to exercise any of these rights, please contact our data protection officer or our customer service by sending an email to data-privacy@lecturio.com or support@lecturio.com. We reserve the right to charge an appropriate fee on the basis of administrative costs in the case of unusually common requests of individual persons.

§ 14 Transfer of personal data to third parties

We collaborate with specific external service providers in order to process your data, for IT hosting services also. We guarantee that the data are transferred with due regard to the applicable data protection provisions. If these service providers are located in a country outside the EU or EEA, we inform them about these provisions in conjunction with the respective functions. These data are also processed in compliance with the prevailing legal norms.

§ 15 Sweepstakes

Separate conditions apply to the collection and processing of personal data when taking part in sweepstakes, contest or competitions organized by us.

§ 16 Miscellaneous

If a third party registered with us by using your email address, please inform us and we will immediately delete your profile.

We reserve the right to update this privacy statement at any time in the course of improving our services and implementing new technologies. We therefore recommend that you reread this privacy statement from time to time.

German law applies.