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Privacy Policy

BERLIN SCHOOL OF BUSINESS & INNOVATION'S PRIVACY NOTICE

Welcome to the Berlin School of Business and Innovation privacy notice.

The Berlin School of Business and Innovation (“BSBI”) respects your privacy and is committed to protecting your personal data. This Privacy Policy describes how we protect your personal data when you visit our websites (regardless of where you access them from), what rights you have as a data subject and how the law protects you.

This Privacy Policy has been prepared in a layer format so that you can click through the individual sections listed below. Please also refer to the Glossary in Section 16 for explanations of certain expressions used in this Privacy Policy.

Purpose of this privacy notice

The purpose of this Privacy Policy is to tell you how BSBI collects and processes your personal data, including all data which you provide via this website any time you:

  • come to our website via a social network like Facebook, Twitter, Instagram or LinkedIn;
  • fill in a call back/enquiry form;
  • register on our website in order to apply for a course or study programme, for a seminar for companies/managers or for CPD courses (online learning, distance learning, on-campus learning), regardless of whether you are submitting the application for yourself or for employees or other members of your organisation who are or become our clients;
  • sign up for marketing materials; or
  • provide us with your personal data by any other means.

It is important that you read this Privacy Policy and all other privacy policies or policies regarding appropriate data processing which we publish with regards to certain instances where we collect or process personal data concerning you in order that you are aware of why and how we use your data.

This Privacy Policy supplements these other policies but does not replace them.

1. Important information and who we are

2. Osano (Cookies)

Our website uses consent technology from Osano to obtain your consent to storing certain cookies on your end device or to the use of certain technologies and to document this consent in compliance with data protection law. The provider of this technology is Osano, Inc., 3800 North Lamar Blvd, Suite 200, Austin, Texas 78756, USA (hereinafter “Osano”).

When you enter our website, a connection is established with Osano servers in order to obtain your consent and other declarations regarding the use of cookies. Osano then stores a cookie in your browser so that any consents you have given or withdrawn can be attributed to you. The data collected during this process are stored until you ask us to erase them, you delete the Osano cookie yourself, or the purpose, for which the data were being stored, is no longer applicable. Mandatory statutory retention periods are unaffected. According to Osano, data concerning European website visitors will remain within the EU as their data are processed exclusively on regional servers. Osano is used to obtain your consent to the use of cookies, as is stipulated by law. The legal basis is Article 6(1), point c) GDPR.

The company is certified according to the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA which is intended to guarantee compliance with European data protection standards for data processed in the USA. All DPF-certified companies undertake to comply with these data protection standards. More information is available from the provider at the following link:

https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt0000000Tct1AAC&status=Active

Data processing by Osano

We have concluded a data processing agreement (DPA) concerning the use of the aforementioned service. This agreement is a legal requirement under data protection law and guarantees that this service provider processes the personal data of our website users according to our instructions and in compliance with the GDPR only.

3. What data we collect from you

Personal data or personal information means all information concerning a person, through which this person can be identified. Therefore, anonymous data do not constitute personal data.

We have put together a list of the different types of personal data which we collect, use, store and transmit. These are:

  • Education-related data means data that are relevant for your admittance to UE and includes data on previous education and schooling, education and training certificates, proof of qualifications, motivational letters, CVs, records of grades and references.
  • Identity data means your first name, name at birth, surname, username or other similar identifying names, civil status, title, date of birth and sex, insurance number, student number, citizenship, residency status, disability declaration, third-party student reference number if this third party is forwarding your data to us, and photographs.
  • Contact data means billing address, term-time address and permanent home address, country of residence, e-mail address and telephone numbers.
  • Emergency contact data for next-of-kin, i.e. names and contact details in the event of an emergency.
  • Employment data (if your employer is financing your education) means employer-related data, start date, end date, insurance number, your position or title, and contact details at your place of work (e-mail address, telephone number and postal address).
  • Financial data means information on student loans, bank details and card details.
  • Marketing and communication data means information on how you would like to receive marketing from us and how you would like us to contact you.
  • Profile data means usernames and passwords, your queries, your purchases or tasks, your interests, your preferences, your feedback and your responses to surveys.
  • Student data means information regarding your term-time and home address, photo ID, area of interest, selected course or study programme at BSBI (or course or study programme of one of our partner organisations), data on your learning progress and your results (seminar attendance and examinations, including mock exam), additional results from the period before the most recent year of study, test papers and overviews of grades, information on your attendance, feedback from lecturers and tutors regarding you or your employees (in the case of a company) (student appraisals), correspondence with BSBI sent to or from you using your BSBI email address, how much you are using BSBI ‘s learning facilities/services (including loans and late returns), data on attendance of events, information on mentor and mentee data, data concerning your attendance at events we have hosted or advertised, learning analyses and profile data, information on disciplinary measures, information on complaints related to students, courses or tutors, (legal) claims of any kind relating to you, extenuating circumstances (personal issues), appeals, and any additional information that is required for professional associations, accreditation bodies or scholarship sponsors.
  • Verification and notifiable data means data concerning the travel destination of college graduates and data concerning students which must be transmitted to third parties for regulatory purposes.
  • Transaction data means information concerning payments to and from you and other information on products and services which you have purchased from us.
  • Technical data means your IP address, log-in details, browser type and version, time-zone setting and location, types and versions of browser plug-ins, operating system and platform, and other technologies on devices you use to access this website.
  • Usage data means URL data, web analytics data concerning how and from where you have reached our websites, what you have searched for, what pages on our websites you have accessed, how long your visit lasts and other information on how you use our websites and the data provided on the same and how you use our products and services; this helps us improve our website for you.
  • Visa data for international students, including passport and details of previous visas, bank statements or other financial information which demonstrates to us that you are compliant with the conditions of your visa.

We also use and forward aggregated data, such as statistical or demographic data, for any and all purposes. Aggregated data may be derived from your personal data but are not legally considered personal data as they do not reveal your identity either directly or indirectly. For example, we compile usage data in order to calculate what percentage of users are using a specific service on our website. However, if we ever combine aggregate data with your personal data or connect these data in such a way that your identity can be inferred, directly or indirectly, we categorise these combined data as personal data and use such in accordance with the provisions of this Privacy Policy.

Special data categories 

When you apply for a course or study programme on our website, we will ask you if you have any disabilities. You are not obliged to tell us but if you do, this will help to give us an idea of how we can fulfil our legal obligations with regards to your disability.

Failure to disclose personal data

If we are obliged to collect personal data by law or on the grounds of the provisions of a contract we have concluded with you and you fail to disclose these data when requested, we will be unable to fulfil the contract we have concluded or wish to conclude with you (e.g. delivering items to you or rendering services for you). In such case, we must cancel the product or service you have ordered, however we will inform you in due course if this is the case.

4. How we collect your personal data

We use different methods to collect data from and concerning you, including:

  • Direct interactions. You share your identity, contact and financial data with us by filling in forms or communicating with us by post, telephone, e-mail or other means. This includes personal data which you disclose when:
    • applying for our products or services;
    • setting up an account on our website;
    • using our website;
    • subscribing to our services or publications;
    • requesting marketing materials;
    • participating in an advertising campaign or survey; or
    • giving us feedback.
  • Automated technologies and interactions. Whenever you interact with our website, we automatically collect technical data concerning your device and your navigation behaviour and patterns. We may also collect personal data by using cookies and other similar technologies. For more information, please refer to our cookie configuration.
  • Third-party or publicly available sources. We receive personal data concerning you from numerous third parties and public sources in accordance with the following:

Technical data from the following parties:

  • Analytics services like Google Analytics, Google Optimizer, Google Webmaster Tools, Google Tag Manager, Facebook, Instagram and other similar services which we will use in future;
  • Advertising networks like Google Advertising Network, Facebook, Instagram, Bing and LinkedIn with registered offices outside of the EU and similar networks, through which we enter into a commercial relationship; and
  • Information research services like Google, Bing and other search engines with registered offices within and outside of the EU, social networks like Facebook, LinkedIn and Instagram with registered offices in the EU, and others who offer similar services.
  • Contact, financial and transaction data from providers of technical services and payment and delivery services, such as Google Analytics, Facebook, Instagram, Bing, LinkedIn and Stripe with registered offices outside of the EU, including similar services, through which we will enter into a commercial relationship in future;
  • Identity and contact data from data collection services
  • Identity and contact data from publicly available sources in the EU, such as the electoral roll.
  • Student data from employees, administrators of other education institutions, from mentees or mentors, from claimants.
  • College, contact, identity, marketing, communication and technical data from (i) publishers who are owners of private websites and have their registered office within and outside of Europe, and (ii) intermediaries and their organisations, such as other universities; and (iii) UCAS (Universities & Colleges Admissions Service).

5. How we use your personal data

We only ever use your personal data where legally permitted. Normally, we use your personal data in the following instances:

  • If we are required fulfil the contract we have concluded or will conclude with you in the near future.
  • If this is necessary within our (or a third party’s) legitimate interest and your interests and basic rights do not override this interest.
  • If we have legal or regulatory obligations which we must fulfil.

Please see the table below for the different legal grounds, on which we process your data.

6. The purposes, for which your personal data are used

Below you will find a description of all the ways, in which your personal data are used and the legal grounds, on which these uses are based. Where applicable, we have also provided information on our legitimate interest.

Depending on the purpose, for which we are using your data, the processing of your personal data may be based on more than one legal ground.

Purpose / ActionType of dataLegal grounds for processing, including on grounds of legitimate interest
Students or future students
To respond to your request for a call back or reply via e-mail and to respond to course enquiries and applications(a) Contact dataFulfilling a contract with you (in the expectation of concluding a contract with you)
To sign you up/register you as a new user and issue an enrolment number/a student ID(a) Identity data
(b) Contact data
(c) College data
Fulfilling a contract with you
Direct marketing relating to discounts and offers for students, university activities and events and services or job prospects and from or relating to professional and trade associations who wish to speak to students about job prospects To advertise the university or faculty using prospectuses which contain images of current students. Direct marketing includes cookie-based remarketing services, the aim of which is to show you targeted adverts based on your internet search.(a) Contact dataConsent
To process your application, and to render services including:
(a) Managing payments, costs and fees
(b) Collecting on moneys that are owed to us
(c) Charging VAT
(a) Identity data
(b) Contact data
(c) Financial data
(d) Transaction data
(e) Marketing and communication data (f) College data
Fulfilling a contract with you Necessary for our legitimate interest (in order to collect on sums owed to us)
To manage our legal relationship with you, including:
(a) Providing learning materials
(b) Requesting a review or participation in a survey
(c) Verifying attendance or change in student status.
(e) Managing complaints and appeals and also matters concerning health, conduct, cheating and plagiarism (prohibited resources).
(f) Awarding scholarships
(a) Identity data
(b) Contact data
(c) Profile data
(d) Marketing and communication data
Fulfilling a contract with you Fulfilling a legal obligation Necessary for our legitimate interest (in order that our documentation is up-to-date and in order to analyse how students are using our products/services)
To review equality of opportunities (for some but not all institutions)Gender, ethnicity, religion and citizenshipLegal obligation
Registration(a) Identity data
(b) Student data
Necessary in order to fulfil a contract
To make adjustments in order to comply with requirements regarding disabilities/medical conditionsHealth dataConsent
To provide health support and first aid, evacuate in case of emergency, conduct risk assessments, review accidentsHealth dataInterests essential to life Consent
Managing emergencies, accidents, healthEmergency contact/Details for next-of-kinInterests essential to life Consent
To improve services, group students according to their performance etc. –Student data (in particular learning analyses)Legitimate interest
Customers (or future customers) of online courses and published media  
To register new customers for online materials(a) Identity data
(b) Contact data
Fulfilling a contract with you
To process/fulfil/deliver a customer order, manage payments and fees To collect moneys owed Billing documents To defend against legal claims brought against us(a) Identity data
(b) Contact data
(c) Financial data
(d) Transaction data (e) Marketing and communication data
Fulfilling a contract with you Necessary for our legitimate interest (in order to collect on sums owed to us or defend against legal claims) Necessary in order to fulfil a legal claim
BSBI customers (including business customers)
To register customer with BSBI(a) Identity data
(b) Contact data
Fulfilling a contract with you
To process/fulfil/deliver our service to you, manage payments and fees, collect moneys owed, billing purposes To defend against legal claims brought against us(a) Identity data
(b) Contact data
(c) Financial data
(d) Transaction data (e) Marketing and communication data
Fulfilling a contract with you Necessary for our legitimate interest (in order to collect on sums owed to us or defend against legal claims) Necessary in order to fulfil a legal claim
BSBI suppliers
To register the supplier as a BSBI supplier(a) Identity data
(b) Contact data
Fulfilling a contract with you
To process and receive goods and services To manage payments and fees, billing purposes, to defend against claims brought against BSBI(a) Identity data
(b) Contact data
(c) Financial data
(d) Transaction data (e) Marketing and communication data
Fulfilling a contract with you Necessary for our legitimate interest (in order to defend against legal claims) Necessary in order to fulfil a legal claim
For all  
HR management (applications for academic positions submitted via web form)(a) Identity data
(b) Contact data
Fulfilling a contract with a candidate
  Customer relationship management, to update the Privacy Policy and notify you of the same, to update our Terms and Conditions and to inform you of the same To ask for your feedback, manage complaints(a) Identity data
(b) Contact data
(c) Profile data
(d) Marketing and communication data
Fulfilling a contract with you Fulfilling a legal obligation Necessary for our legitimate interest (continuous improvement/updating documents/analysing behaviour patterns among customers)
To enable respondents to participate in a survey(a) Identity data
(b) Contact data
(c) Profile data
(d) Usage data
(e) Marketing and communication data
  Necessary for our legitimate interest (continuous improvement/updating documents/analysing behaviour patterns among customers) Consent
To manage and protect our company and our website (including troubleshooting, data analysis, tests, system maintenance, support, reporting and data hosting)(a) Identity data
(b) Contact data
(c) Technical data
Necessary for our legitimate interest (for managing our operations, providing administrative and IT services, network security, anti-fraud and in the context of reorganising the company or a restructuring of the group) Necessary in order to fulfil a legal obligation
To provide you with relevant website content and advertising and to measure and understand the effectiveness of the advertising we show you(a) Identity data
(b) Contact data
(c) Profile data
(d) Usage data
(e) Marketing and communication data (f) Technical data
Necessary for our legitimate interest (in order to analyse how customers use our products/services in order to develop these, in order to grow our business and in order to adapt our marketing strategy) Consent obtained through cookies
To use data analytics services in order to improve our website, our products/services, our marketing, our business relationships and the experiences of our students and partners(a) Technical data (b) Usage dataNecessary for our legitimate interest (in order to define customer types for our products/services so that our website is up-to-date and contains relevant information, in order to grow our business and in order to adapt our marketing strategy)
To make suggestions and recommendations regarding goods and services that may be of interest to you(a) Identity data
(b) Contact data
(c) Technical data (d) Usage data
(e) Profile data
Necessary for our legitimate interest (in order to develop our products/services and in order to grow our business) Consent

7. How we use confidential personal data (special category data)

We are legally obliged to fulfil additional requirements with respect to collecting, storing and using personal data that are regarded as “special category data”. We have appropriate security measures in place which we follow by law whenever processing such data. We process special categories of personal data in the following instances:

Purpose/ActionType of dataLegal grounds for processing
Students or future students  
In order to register you as a student, we must verify your residency status with BSBICitizenship data Residency data (information from visas and passports)(a) Fulfilling a contract with you
(b) Complying with legal obligations, e.g. with respect to German immigration authorities (and others)
To make necessary adjustments and provide necessary support in accordance with the corresponding learning needsData on disabilities Special education needs(a) Fulfilling our legal obligations (pursuant to German Equality Act (Gleichstellungsgesetz) of 2010)
(b) Explicit consent (information is provided voluntarily)
To review student absences* To process applications for extenuating circumstances To process applications for suspending or deferring studies To document dietary requirementsMedical data/Health data Doctor’s certificates Patient records (under certain circumstances)(a) Fulfilling a contract with you
(b) Explicit consent (information is provided voluntarily) (c) * Sometimes a visa states that a student must achieve a minimum level of attendance; in this case, we will request a doctor’s note for any absences so that we do not breach our obligations with respect to the German Foreign Office (Auswärtiges Amt)

The above information must also be used as legal grounds where applicable due to the enforcement of legal claims or in order to protect your interests (or the interests of another person) (if you lack the capacity to give consent, e.g. because of a health issue which makes it impossible for you to communicate).

Consent

You are not required to consent to specific types of processing in order to become a student with us. However, if you decide not to give us any consent, you will be unable to use certain services, such as support services.

We do not require your consent in cases where we use special categories of data pursuant to our legal obligations (and where we describe this in our written guidelines). In rare cases, we will ask for your explicit (written) consent to use special category data. When doing so, we will ensure that you receive a detailed explanation of what data we require and the reasons for this. You can then use this information to decide whether or not you wish to consent.

Marketing

We make every effort to ensure that you can choose if and how certain personal data are used, in particular with regards to marketing and advertising. We always give you the opportunity to decide if and how we use your personal data.

Marketing from us

You will receive marketing from us if you have requested information from us or if you have purchased products or services from us or if you have provided your contact details in a survey or feedback form and you have consented to the sending of marketing materials in this context (opt-in).

Opt-out

We will only ever send you marketing e-mails if you have explicitly consented (opt-in). You can ask us to stop sending you marketing at any time by clicking on the Opt-out/Unsubscribe links in the marketing materials you receive or by contacting the DPO directly at dpo@berlinsbi.com.

If you opt out of marketing or update your preferences, we will still keep those data which you have sent us when applying for a course or study programme or when purchasing other services or materials from us.

Cookies

You can adjust your browser settings to block all or some browser cookies or to receive a notification any time websites place cookies or access cookies. Please note that disabling or blocking cookies may affect the functionality of some parts of this website or prevent you from accessing the website entirely.

Change of purpose

We only ever use your personal data for those purposes, for which we collected them, unless we come to the conclusion, at our reasonable discretion, that we must use the data for another reason and that this reason is consistent with the original purpose (unless our processing was based on the legal grounds of consent). If you would like an explanation regarding the extent to which processing for this new purpose is consistent with the original purpose, please contact our DPO.

Any time we have to use your personal data for a purpose other than the specified purpose, we will notify you and explain the legal grounds which permit us to do so. Please note that we will process your personal data in accordance with the above regulations without your knowledge or consent, insofar as this is legally required or permitted.

8. Disclosing your personal data

We are required to disclose your personal data to the parties indicated below on the grounds listed in the table in Section 5.

  • Internal third parties pursuant to the Glossary.
  • External third parties pursuant to the Glossary.
  • Certain third parties as indicated in the Glossary.
  • Third parties, to whom we decide to sell or assign parts of our company or our assets or with whom we decide to merge. Alternatively, we may seek to buy other companies or merge with such. In the event of a change affecting our company, the new owners may use your personal data in the manner described in this Privacy Policy.

We require of all third parties that they observe the security of your personal data and treat such in accordance with the applicable law. We do not permit our third-party service providers to use your personal data for their own purposes and we permit them only to process your personal data for specific purposes and in accordance with our instructions.

9. International data transfers

We forward your data within the GUS Group. This involves transferring your data outside of the European Economic Area (EEA).

Some of our external third parties have their registered office outside of the European Economic Area (EEA), such that the processing of your personal data by these parties involves the transfer of data outside of the EEA.

Whenever we transfer your personal data outside of the EEA, we ensure that your data are protected in a comparable manner by ensuring that the following security measures are implemented as a minimum:

  • We only transfer your personal data to countries which, in the opinion of the European Commission, have an adequate level of data protection. You can get more information from the European Commission: Data protection adequacy in non-EU countries.
  • When utilising certain service providers, we use special contracts which have been approved by the European Commission and which provide for the same level of data protection as in Europe. You can get more information from the European Commission: Model contracts for transfer of personal data to third countries.
  • When using providers with registered offices in the USA, we only transfer data to these providers if they are subject to the regulations of the EU-US Privacy Shield which requires them to guarantee a comparable level of protection for personal data being transmitted between Europe and the USA. You can get more information from the European Commission: EU-US Privacy Shield.
  • You have explicitly consented to the relevant transfer once you have been informed that this transfer involves risks for you because the level of data protection is not adequate and appropriate security measures have not been taken.
  • The transfer is necessary in order to fulfil a contract between you and us as controller or in order to take steps at your request prior to entering into a contract.
  • The transfer is necessary in order to conclude or fulfil a contract which was concluded in your interest between you and us as controller and another natural or legal person.
  • The transfer is necessary for good cause in the public interest.
  • The transfer is necessary in order to establish, exercise or defend legal claims.
  • The transfer is necessary in order to protect your vital interests or the vital interests of other persons, insofar as you do not possess the physical or legal capacity to consent.

The transfer is conducted on the basis of a directory which, pursuant to the law of the European Union or a Member State, serves to inform the public and which is available to the general public or to persons who can demonstrate a legitimate interest, but only insofar as the requirements for inspection as set out in EU law or the law of a Member State are fulfilled in each case.

10. Data security

We have taken appropriate security measures to prevent the accidental loss, unauthorised use, modification and disclosure of or access to your personal data. We also restrict access to your personal data to those employees, agents, contractors and other third parties who require knowledge of such for business purposes. They process your personal data in accordance with our instructions only and are subject to confidentiality.

We have put in place procedures for reacting in the event that there is a suspicion that the security of your personal data may have been breached and we will inform you and all relevant regulatory authorities of any breaches, insofar as we are legally obliged to do so.

11. Data storage

How long do we use your personal data for?

We store your personal data only for as long as this is necessary for achieving the purposes, for which they were collected, including for the purposes of fulfilling legal, invoicing or reporting requirements.

In some cases, you may ask us to erase your data: please see below for more details. In some cases, we anonymise your personal data (such that they can no longer be attributed to you) for research and statistical purposes; in such cases, we use this information indefinitely without informing you.

In certain cases, you have specific rights with regards to your personal data on the grounds of data protection regulations. Please click on the links below to find out more about these rights:

13. Social media

Facebook

14. Analytical tools and advertising

15. Plug-ins and tools

16. glossary

  • Services providers who act as data processors in England and Germany and render IT and system administration services.
  • Professional consultants who act jointly as a controller or data processor, including solicitors, bankers, auditors and insurers, who have their registered offices at different locations around the world and who render services in the areas of consulting, banking, law, insurance and accounting.
  • HM Revenue & Customs, regulatory authorities and other authorities which act as data processing authorities or jointly as data supervisory authorities, who have their registered office in the United Kingdom and in other countries, and who, in certain cases, require records of data processing activities.
  • Employers who request an assessment from BSBI.
  • External examiners for the purposes of examinations, grading and evaluation of grades
  • Partners of the decision-making committees – in order to manage the administrative aspects of registering students on study programmes
  • Professional associations/Funding bodies/Student loans companies
  • Advertising partners (e.g. AgenturWebfox GmbH, Facebook Lookalikes)
  • Other universities, employers, future employers, providers of training contracts or assistant positions