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The WBS GRUPPE (WBS), which includes WBS TRAINING AG, WBS TRAINING SCHULEN gGmbH and app2job GmbH, is pleased to be able to offer the following basic information about data protection and how your personal data is handled.
The data controller as defined by data protection law is the relevant WBS GROUP company as described in Sections 1.1 to 1.3.
You can reach our data protection officer using the following contact details:
DataCo GmbH
+49 (0)228 89 7400 45840
datenschutz@dataguard.de
www.dataguard.de
The data controller pursuant to Article 4 Paragraph 7 of the EU General Data Protection Regulation (GDPR) is WBS TRAINING AG, Lorenzweg 5, 12099 Berlin, Germany; telephone: +49 (0)30 695450400; kontakt@wbstraining.de
This data controller is responsible for the following websites:
The data controller pursuant to Article 4 Paragraph 7 GDPR is WBS TRAINING SCHULEN gGmbH, Lorenzweg 5, 12099 Berlin, Germany; telephone: +49 (0)30 695450400, kontakt@wbs-schulen.de.
This data controller is responsible for the following websites:
The data controller pursuant to Article 4 Paragraph 7 GDPR is app2job GmbH, Weiskopffstrasse 16/17, 12459 Berlin, Germany; telephone: +49 (0)30 695450424; beratung@app2job.de
Please note: Information on in-house events run by WBS TRAINING is available in Section 2.3.
When you contact us using the contact options provided on the website, on social media (e.g. LinkedIn, XING), by email or by visiting one of our WBS locations, we collect various personal data, depending on whether you are receiving a consultation or are concluding a contract with us:
If you book an educational course, training, continuing education course or coaching session with us, we collect and process the data that is necessary to execute the contract. The scope of the data depends on the product and on your funding situation. The types of data that may be involved are described below. The precise scope will depend on the form used and your particular circumstances. If you contact us as a prospective student, we collect much of this data in the course of initiating a contract. The legal basis for the processing of data in this case is Article 6 Paragraph 1(b) GDPR. Unfortunately, we are unable to proceed with your consultancy appointment if you do not provide the required data. Additional information is provided on a voluntary basis and will be processed based on your consent.
Depending on whether other partners are involved in your qualification course, we collect the following data so we are able to provide our contractually agreed services (Article 6 Paragraph 1(b) GDPR):
If you have contacted us through our partner app2Job, we obtain the data collected there about you (Article 6 Paragraph 1(f) GDPR).
It may also be necessary for personal data to be exchanged between WBS TRAINING AG, WBS TRAINING SCHULEN gGmbH and app2Job GmbH for the purpose of processing your query.
We inform your funding source regarding the progress of your participation and about any special events. Only data necessary for both parties to complete their tasks is sent (e.g. contractual documents, dates of absence, certificates of incapacity to work, certificates, participation reports, information on conduct and performance relevant to the measure’s objective or incorporation). We are bound to comply with this requirement by Sections 81, 183 and 318 SGB III. The legal basis is Article 6 Paragraph 1(c) GDPR in conjunction with the provisions mentioned above under German law. If special categories of personal data are involved when sending data, this is on the basis of Article 9 Paragraph 2(b) GDPR in conjunction with the provisions mentioned above under German law. If you receive benefits for participation, interim and final reports and, where applicable, psychological fitness reports are also sent. In the event of special leave due to disability, we store a copy of the documentation you provide regarding your disability and send this information to your source of funding.
Only the data necessary for the course/coaching is sent to freelance trainers/coaches hired to conduct your qualification course or coaching.
To access digital learning tools, it may be necessary to send the personal data we require for registration to the relevant publishers. These providers have been verified in terms of their compliance with German and European data protection laws.
As part of quality controls conducted by outside certifiers (including DQS) or the audit service of the German Federal Employment Agency, your data is sent to the auditing organisation, if applicable.
Depending on whether other partners are also involved in your qualification course, we send the data necessary for the task in question (pursuant to Article 6 Paragraph 1(b) GDPR) to the following partners, where applicable, for the purpose of executing the contract:
You can recognise products that are carried out entirely by one of our cooperation partners by a corresponding note in the product flyer. If you are interested in such a product, we will transmit your data (first name, surname, telephone number, e-mail address) after your express and informed consent together with the product interest to the respective cooperation partner so that you can be contacted by them for the purpose of initiating the contract. This only takes place if you have expressly consented to this transmission. The legal basis is therefore your consent (Article 6 Paragraph 1 (a) GDPR).
Disclosure to potential employers:
If you have explicitly consented, we use data regarding your suitability (CV, qualifications booked) to compare with enquiries from potential employers and, if applicable, to send this data to the company making the enquiry.
We store your personal data as long as it is required to meet our statutory and contractual obligations.
If it is no longer necessary to store your data to meet our contractual or statutory obligations, your data will be erased unless further processing is necessary to fulfil retention obligations or protect our legitimate interests.
Our websites offer you the option to subscribe to our newsletter. We use what is known as a double-opt-in procedure when you subscribe to our newsletter. This means that when you subscribe, we send a confirmation email to the email address you provided asking you to confirm that you want to subscribe. If you do not confirm your registration within 30 days, your information is automatically erased. In order to document and verify a specific newsletter subscription, we store the data transmitted when subscribing to the newsletter, including the source IP address, a time stamp and the IP address of the receiving server. We also record the activation of the confirmation link, including the source IP address, a time stamp and the IP address of the receiving server.
If you have granted us your consent to receiving marketing communications, we store your email address for the purpose of sending you this information. The legal basis is Article 6 Paragraph 1(a) GDPR. You may revoke your consent at any time. You can revoke your consent by clicking on the link provided in each newsletter email or by sending an email to datenschutz@wbs-gruppe.de. Revoking your consent does not affect the legality of the processing carried out before your consent was revoked.
In addition to your consent, we process your email address for the purpose of marketing similar proprietary products and related customer satisfaction surveys, provided you are an existing customer. The legal basis is Article 6 Paragraph 1(f) GDPR in conjunction with Section 7 Paragraph 3 of the German Act Against Unfair Practices (Gesetz gegen den unlauteren Wettbewerb [UWG]). Informing our existing customers about new products and services offered is a legitimate interest. You are entitled to object to this at any time, free of charge. Simply send an email to datenschutz@wbs-gruppe.de.
We would also like to facilitate independent quality checks by institutes. As such, we may hire other companies to conduct customer surveys, so you might be contacted by a company other than WBS. We conclude contracts for data processing with these companies in compliance with the provisions of the GDPR.
We generally retain data that is required for processing for marketing purposes until you revoke your consent or object to this type of use. Except where you revoke your consent or object to processing, there is no set rule regarding the retention period for data used for marketing purposes. Instead, the retention period depends on whether it is necessary for us to store that data to contact you on a marketing basis. Once you revoke your consent or object to processing, we continue to store the required information for a reasonable period of time on the basis of Article 6 Paragraph 1(f) GDPR. Being able to provide evidence and furnish proof should we need to is a legitimate interest under the provision mentioned above.
Contact details subject to an objection to processing will continue to be stored in a blocked form on a marketing blacklist. By doing so, we can ensure that you do not receive any further marketing material from us, either by post or by electronic mail. The legal basis is Article 6 Paragraph 1(f) GDPR. Your desire not to receive any further marketing communications in future constitutes a legitimate interest under the provision mentioned above. If you do not agree to this, please do let us know. We will then permanently erase your data. However, in this case, we will no longer be able to fully ensure that you will not receive any marketing communications from us in future.
Depending on the product and depending on the agreement in place with your employer, we collect the following data when you attend an in-house event. In general, some of this data is collected by your employer.
The purpose of processing is to fulfil contractual obligations. The legal basis for the processing of data in this case is Article 6 Paragraph 1(b) GDPR.
Depending on the agreement with your employer, we send your dates of attendance and absence, results of training sessions and recordings of events to your employer, if applicable, provided this is necessary to fulfil the contract.
We store your personal data as long as it is required to meet our statutory and contractual obligations.
If it is no longer necessary to store your data to meet our contractual or statutory obligations, your data will be erased unless further processing is necessary to fulfil retention obligations or protect our legitimate interests.
If you are the contact person for your organisation and you contact WBS (e.g. as a corporate client, partner or supplier), we collect the following data:
The purpose of processing is to fulfil contractual obligations. The legal basis for processing is therefore Article 6 Paragraph 1(b) GDPR.
We store your personal data as long as it is required to meet our statutory and contractual obligations.
If it is no longer necessary to store your data to meet our contractual or statutory obligations, your data will be erased unless further processing is necessary to fulfil retention obligations or protect our legitimate interests.
If you use the “Refer a friend” programme as a participant or graduate of a continuing education course at WBS Training, the terms and conditions of participation set out on the website apply. Details can be found on our website. To be able to verify compliance with the terms and conditions of participation, we need to process personal data from both you and the person to whom you have provided the referral. We only collect the data listed on the programme form, which can be accessed through the above website. Required information is marked with an *.
Referrer
If you wish to take part in the “Refer a friend” programme as a referrer, we need your first name, surname, email address, course title and WBS location. We process this data to operate the referral programme, specifically to verify your eligibility to participate and to send you your reward when a referral is successful. Data is therefore processed on the basis of Article 6 Paragraph 1(b) GDPR.
Referral customer
If you have received a referral as part of the referral programme, this means we have received your personal data (name, surname, email address) from the referrer for the purpose of contacting you and extending you an offer. In line with our terms and conditions of participation, the referrer is required to obtain your consent to data processing in advance and confirm that they have done so. Your personal data is processed on the basis of Article 6 Paragraph 1(f) GDPR. Processing in this case is in our legitimate interest since it is the only way to grant the reward and no conflicting interests are apparent.
If you would like to prematurely end your participation in the “Refer a friend” programme, please inform us this by sending an email to freundewerben@wbstraining.de. We then erase the data stored for the purpose of the “Refer a friend” programme.
When using our website purely for informational purposes, i.e. if you do not register or otherwise send us information, we only collect the data your browser transmits to our server, including any personal data that includes. When you view our website, we collect the following data, which we require for technical reasons for the proper display of our website and to ensure its stability and security:
If the data processed is personal data, the legal basis for processing is Article 6 Paragraph 1(f) GDPR. Under the above provision, our legitimate interest here is in making our website technically available and securing it.
We also use cookies, tracking tools, targeting methods and social media plugins on our website. The specific methods used and how we use your data in the process are explained in greater detail in Section 5 below.
The data collected is stored for a period of six (6) months, after which it is automatically erased. For information on routine erasure and the tools used, please see the relevant paragraphs in Section 5.
Our website www.wbs-gruppe.de gives you the option to apply for a job at WBS online. In addition to the information provided as part of the application form, we also collect information about your educational background and professional career during the application process. Any documents sent with the application (covering letter, CV, transcripts, letters of reference and other documentation) and the information those documents contain are stored. Applicants’ personal data may only be processed for the purpose of the application process if necessary to decide whether to enter into an employment relationship with us.
For the efficient implementation of application procedures, we use an applicant management system from softgarden e-Recruiting GmbH, Tauentzienstr. 14, 10789 Berlin (contact: datenschutz@softgarden.de), which operates the applicant management system as a processor within the meaning of Art. 4 No. 8 GDPR. A contract for order processing in accordance with Art. 28 GDPR has been concluded with the provider, which ensures compliance with data protection regulations.
We store your personal data as long as it is required to meet our statutory and contractual obligations.
If it is no longer necessary to store your data to meet our contractual or statutory obligations, your data will be erased unless further processing is necessary to fulfil retention obligations or protect our legitimate interests.
If you do not consent to your application being stored for a longer period, your profile and your personal data will be erased automatically, normally no more than six (6) months after receiving your application.
If you have applied for a specific job vacancy and we decide we would like to keep your personal data for future job openings, we will always request your prior consent before doing so.
To be informed about new vacancies, you can subscribe to the job newsletter or have suitable vacancies displayed on our career board (RSS feed). You can define your subscription in more detail by specifying the desired job and location. Your e-mail address is also required for the subscription. The legal basis for this is your consent to receive the newsletter in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent to receive the newsletter at any time via the unsubscribe link in the newsletter (opt-out). No personal data is processed via the RSS feed itself to inform you about new job advertisements.To be informed about new vacancies, you can subscribe to the job newsletter or have suitable vacancies displayed on our career board (RSS feed). You can define your subscription in more detail by specifying the desired job and location. Your e-mail address is also required for the subscription. The legal basis for this is your consent to receive the newsletter in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent to receive the newsletter at any time via the unsubscribe link in the newsletter (opt-out). No personal data is processed via the RSS feed itself to inform you about new job advertisements.
In order to manage your applications more easily and efficiently, softgarden offers the option of registering for the softgarden network and creating an account for this purpose. The softgarden network is a cross-customer talent pool of softgarden. You can configure your network account individually and also view the status of your applications. You can enter the following details: Title, surname, first name, date of birth, profile picture, contact details (including e-mail address and telephone number), application documents (e.g. CV, education, professional experience, language skills), areas of interest (job category, career level and desired location). The legal basis for the creation of the softgarden network account is your consent, Art. 6 para. 1 lit. a) GDPR. You can find more information about the softgarden Network here: https://softgarden.com/de/datenschutz-network/.
At various stages of the application process, softgarden will give you the opportunity to provide feedback on your salary expectations and the salaries offered to you. The information provided will be processed anonymously and without linking it to your name and contact details. softgarden processes this data anonymously for its own purposes (statistics, analysis, studies) and is responsible for this processing within the meaning of Art. 4 No. 7 GDPR. Processing only takes place with your consent through participation and on a purely voluntary basis. The legal basis is Art. 6 para. 1 sentence 1 lit. a) GDPR.
At the end of the application process, softgarden may send you an invitation to a survey via a link. The survey takes place via a service provided by easyfeedback GmbH in order to query the application experience. softgarden conducts this survey as the controller within the meaning of Art. 4 No. 7 GDPR and processes the collected data anonymously for its own purposes (statistics, analysis, studies) and for the further development of softgarden products. The collection of survey data is secured by SSL encryption as standard and softgarden does not establish any personal reference during processing. The survey can be canceled at any time. The data processed up to the time of termination can be used for the purposes stated. Your participation in the survey is purely voluntary and by participating you declare your consent, without which your participation is not possible, Art. 6 para. 1 lit. a) GDPR. The data is processed anonymously. Anonymized data is subsequently not subject to the material scope of the GDPR. You can find more information about easyfeedback’s data protection in the following information: https://easy-feedback.de/privacy/datenschutzerklaerung.
We use an integrated service of Cronofy Limited, 9a Beck Street, Nottingham, NG1 1EQ, UK for the purpose of scheduling and inviting appointments. If we invite you to a meeting using this function, you will receive an appointment invitation created via Cronofy by email. This will include your e-mail address and the title of the appointment, a description and a location where the appointment is to take place. No further personal data will be transmitted by you to Cronofy. The legal basis for the processing is Art. 6 para. 1 lit. f GDPR in order to integrate the appointment scheduling into our applicant management system and to plan and manage job interviews and other appointments more efficiently. The data processing takes place in encrypted form in an isolated environment on a server in Germany. Data transfer to third countries (USA) cannot be ruled out. Adequate security standards for data processing have been agreed with the provider and verified by the provider. Further information can also be found at the following link: Scheduling Platform for Business | Cronofy the scheduling experts. However, if you do not wish to have your data processed by Cronofy or require further information, please indicate this in advance of coordinating your appointment.
We process and analyze documents uploaded by you in order to extract CV data and convert it into a structured form (so-called “CV parsing”). To ensure data subject rights and security standards, an order processing contract has been concluded with the service provider. The processor is the ISO27001-certified provider Textkernel B.V. Nieuwendammerkade 26 A 5, (1022AB) Amsterdam, Netherlands. The data processing takes place on a server in Germany in a secure environment. The legal basis for the processing is Section 26 (1) BDSG and Art. 6 (1) sentence 1 lit. f) GDPR in order to initiate an employment relationship and to make the application process efficient for you. Personal data will not be transferred to third countries. Your data is routinely deleted from the cache once a week.
In accordance with § 2 (4) of the Akkreditierungs – und Zulassungsverordnung Arbeitsförderung [AZAV], we are required to ensure and continuously improve the quality of our certified trainings through targeted and systematic procedures and measures. This includes regular surveys of participants according to § 2 (4) number 9 AZAV. Therefore, surveys are regularly conducted. The data is used exclusively for the purpose of quality control and pseudonymized after collection. It will not be disclosed to third parties. The data from this survey will be combined with other pseudonymized data stored by us for analysis purposes. Only a few employees from the quality management have access to assign feedback to pseudonyms in order to create evaluations for quality control purposes. Only these employees bound by confidentiality obligations are able to establish a personal reference. For other employees (e.g. Community Management, Instructors), it is not intended to draw conclusions about individuals. The legal basis for processing is Art. 6 (1) lit.c GDPR in conjunction with § 2 (4) number 9 AZAV. Satisfaction surveys conducted in non-AZAV certified measures are based on our legitimate interest according to Art. 6 Abs.lit.f GDPR, which lies in using the results for improving our services. You can object at any time against the use of your data for satisfaction surveys by sending a message to datenschutz@wbs-gruppe.de.
We would also like to facilitate independent quality checks by institutes. As such, we may hire other companies to conduct customer surveys, so you might be contacted by a company other than WBS. We conclude contracts for data processing with these companies in compliance with the provisions of the GDPR.
For some products, recorded training sessions are included as part of the services contracted. In these cases, training sessions are recorded to facilitate participation when convenient for the viewer. The recording includes all comments made, requests to speak, questions, etc., with the relevant name and surname displayed. The legal basis for processing is Article 6 Paragraph 1(b) GDPR (performance of a contract). Camera usage is on a voluntary basis (consent as per Article 6 Paragraph 1(a)). The recording is provided to all participants for a limited time (usually four (4) weeks).
We sometimes use third-party service providers to process your data. These third parties may have access to personal data, provided this is necessary to complete their tasks. In terms of contracted data processing as stipulated in Article 28 GDPR, we ensure that these providers are similarly bound by the provisions of data protection laws. If service providers are data controllers as defined by the GDPR, they are bound by a duty of confidentiality and must comply with the statutory data protection regulations. Please also take note of the privacy notices for each service provider (see Section 5). The service provider in each case is responsible for the content of third-party services, whereas we verify that their services are in compliance with the statutory requirements to a reasonable extent.
It is important to us that your data be processed within the EU/EEA. However, we may use service providers that process data outside of the EU/EEA. In these cases, we ensure that the recipient has an adequate level of data protection in place before transmitting your personal data. This means that we are able to achieve a level of data protection commensurate with EU standards through what are known as EU standard contractual clauses or an adequacy decision by the EU Commission. Specific guarantees are explained with each procedure.
To exercise your rights as a data subject, simply send a message to datenschutz@wbs-gruppe.de or one of the other contact addresses listed in Section 1.
If data processing is carried out on the basis of your consent, you may revoke your consent to your data being processed at any time with future effect without incurring any detrimental consequences. This does not affect the lawfulness of any data processing that was carried out before you revoked your consent.
Under Article 21 Paragraph 1 GDPR, you have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1(e) (data processing in the public interest) or (f) (data processing to safeguard a legitimate interest) GDPR. This also applies to any profiling based on this provision.
If we process your personal data in order to engage in direct marketing, you have the right under Article 21 Paragraph 2 GDPR to lodge an objection against the processing of the personal data relating to you for the purpose of such marketing at any time. This also applies to profiling where this is connected to this kind of direct marketing.
You are further entitled to exercise the following rights, provided the legal requirements are met in each case:
The following web-based technology is generally used on the WBS Group’s websites. You can find out which technology is actually being used by looking at the overview of cookie consents on the website in question.
When using our website, cookies are stored on the user’s device and other similar tracking technologies are used. Cookies are small data records in a database maintained by your browser or text files your browser generates automatically and are stored on your device (laptop, tablet, smartphone, etc.), They provide certain information to the organisation that sets the cookies (in this case, us). For the sake of readability, other tracking technologies that work similarly to cookies and whose functionality is explained in the sections below are also referred to as cookies. Cookies do not harm your device and do not contain viruses, Trojan horses or other malware. They serve to make our online services more user-friendly and effective overall.
This website uses the following types of cookies and tracking, the scope and functionality of which are explained below:
These cookies are erased automatically when you close your browser or log out. These cookies store what is known as a session ID. This allows us to assign various requests from your browser to a common session. This enables us to recognise your computer if you return to our website.
Persistent cookies are automatically erased after a given amount of time, which may differ depending on the cookie. You can erase these cookies at any time by adjusting your browser’s privacy settings.
Flash cookies are set by the Adobe Flash plugin, which is installed in your browser. These objects store the necessary data, regardless of the browser you use, which means the data can be used across different browsers. They have no automatic expiry date. Depending on your browser, Flash cookies can be managed (e.g. erased) like other cookies, or they may not be visible in your browser’s cookie management system. If you do not want any Flash cookie processing to be carried out, adjust your Flash Player settings to prevent this or install a relevant add-on to your browser.
Web storage is used to store data in your browser for the purposes listed below. There are two main types of storage: Local storage for persistent data (with no expiry date) and session storage for session data (which is erased once the browser window is closed). You can erase this data by adjusting your browser’s developer options.
This method typically involves running a tracking script on the website, which requests a tracking pixel from the web analytics tool provider. Information for the purposes listed below is also sent and, where applicable, a cookie for the web analytics tool provider is set. If there is an existing cookie, this information is added to the information in the cookie. You can remove these cookies as explained above.
The necessary or essential cookies listed later in this text allow us to store the connection status of your account and to adjust the website to tailor it to your device. For example, they enable you to have direct access to personal and protected zones on our website with a user name or data you have previously entered. The data processed by these cookies is necessary for the purposes stated in order to safeguard our legitimate interests as well as those of third parties in line with Article 6 Paragraph 1(f) GDPR.
The analytical cookies listed help us to optimise our website to make it more convenient for you to use. For example, we use session cookies to recognise that you have already visited specific pages on our website. These cookies store what is known as a session ID. This allows us to assign various requests from your browser to a common session. This enables us to recognise your computer if you return to our website.
We also use cookies to record the use of our website for statistical reasons and evaluate it for the purpose of optimising our products and services for you. These cookies allow us to automatically recognise that you have already visited our website on a previous occasion when you visit our website again. We also use the cookies to be able to identify you for follow-up visits if you have an account with us. Otherwise, you will need to log in again each time you visit our website.
We can also use cookies to store your preferences. This allows us or third-party providers running features on our website to store your settings on our website or individual features. When you later return to our website, your previous settings are restored.
We aim to use these tracking measures to continuously optimise the design of our website to suit your needs. We also use these tracking measures to record the use of our website for statistical purposes. We also use the data to optimise advertising content. The purposes for data processing and the categories of data being processed can be found in the description of each tracking tool and the overview of cookie consents.
Data processing in connection with the setting of analytical, statistical or preference cookies and tracking cookies is conducted on the basis of your consent (Article 6 Paragraph 1(a) GDPR). More information is available in the relevant sections covering web analytics tools in this Privacy Notice.
The legal basis for storing information in your terminal device or access to information that is already stored in your device is your consent in accordance with § 25 Para. 1 TTDSG [Federal Act on the Regulation of Data Protection and Privacy in Telecommunications and Telemedia]. In the event that it is absolutely necessary to store information in your terminal device or access information already stored in your device so that we can provide a telemedia service that you have expressly requested, the legal basis is § 25 Para. 2 (2) TTDSG.
The legal basis for the processing of personal data using cookies that are not necessary from a technical perspective is your consent in accordance with Art. 6 Para. 1 S. 1(a) GDPR.
The legal basis for the processing of personal data using technically necessary cookies is our legitimate interest in accordance with Art. 6 Para. 1 S. 1(f) GDPR.
We usually send our personalised newsletter by using newsletter provider CleverReach by CleverReach GmbH & Co. KG, Mühlenstr. 43, 2618 Rastede, Germany (“CleverReach”). CleverReach is a member of the Certified Senders Alliance, which has set out its own internal guidelines for admissible email marketing. We have concluded a data processing agreement with CleverReach as per Article 28 GDPR.
We use CleverReach to measure and analyse responses to our newsletter. We have configured CleverReach such that data can only be analysed on an anonymous and aggregated basis. These settings also prevent cookies and your full IP address from being collected and processed. We also embed the Google Analytics tool in the newsletter so we can analyse the correlation between the newsletter and the purchase of a product. This is done by attaching the appropriate parameters to all links in the newsletter. If you click the link, we place a small text file (cookie) on your computer. This allows us to pinpoint the newsletter as the starting point for your visit to our website. If you order a product within 14 days, this information is displayed to us.
CleverReach can embed Twitter, Facebook, LinkedIn and Xing social media buttons in the newsletter on our behalf. Clicking on one of these buttons establishes a direct connection to the button provider’s servers.
More information about data protection at CleverReach is available in its Privacy Policy.
This website uses Mouseflow, a web analytics tool operated by Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark, to record individual visits selected at random (and only with an anonymised IP address) on the basis of your consent pursuant to Article 6 Paragraph 1(a) GDPR. It generates a log of mouse movements, mouse clicks and keyboard interaction with a view to replaying individual visits to this website based on random samples, known as session replays, and to evaluate these session replays using heat maps to develop website optimisation potential. Mouseflow also hosts multiple choice surveys to record user satisfaction with the website or specific content. The conducting of these surveys and survey participation are also recorded in the cookie. The cookie generated by Mouseflow is erased after a period of 90 days.
The data recorded by Mouseflow is not personal data. In particular, Mouseflow only processes your IP address in an anonymised form. The information is stored for a period of three (3) months and is not disclosed to third parties. The data collected is stored and processed within the EU. If you do not want Mouseflow to record your data, in addition to revoking your consent, you can object to this on any website that uses Mouseflow by visiting the following link: https://mouseflow.com/opt-out/.
We use tools provided by Hubspot, Inc., 25 First Street, Cambridge, MA 02141 USA, and its affiliated companies (collectively referred to as “Hubspot”) on our websites to send our newsletter, receive queries through our website, and operate landing pages. These tools use cookies on our website to collect the following personal data when you use the website:
Data is processed in the US or Ireland. HubSpot processes data on our behalf. We have concluded a data processing agreement with HubSpot. This agreement serves to ensure that HubSpot processes the data in compliance with the EU General Data Protection Regulation and to guarantee the rights of data subjects. HubSpot does not use customer data to contact you itself unless you arrange for this to happen or otherwise permit it. EU standard data protection clauses are included in the data processing agreement with Hubspot (Art. 46 Para. 2 S. 1(c) GDPR). These are classed as an appropriate guarantee to protect the transfer and processing of personal data outside the EU. More information about data processing at HubSpot is available here: https://legal.hubspot.com/product-privacy-policy The legal basis for setting cookies and processing your data is your consent. You may revoke your consent at any time with future effect. Revoking your consent does not affect the lawfulness of the processing carried out before your consent was revoked.
This website uses the Google Tag Manager tool (“GTM”), operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use GTM to manage the tools we are informing you about in this Privacy Notice. For details regarding these tools, please refer to the information about the specific tool.
GTM is embedded using a script and a variant for systems with JavaScript disabled. It is loaded from the domain googletagmanager.com. It loads tools from Google or third-party providers, which in turn may collect data or load cookies (see the cookie declaration in this Privacy Notice). GTM itself does not access this data.
More information about GTM is available in the terms of use for this product.
The legal basis for setting cookies and processing your data is your consent. You can revoke your consent at any time with future effect. This does not affect the lawfulness of the processing up to the time of revocation.
We use the web analysis tool ‘Matomo’ for further statistical analysis of our website. Matomo is a service provided by InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand. Matomo creates use profiles based on pseudonyms and stores cookies on your device for this purpose. The software is configured in such a way that IP addresses are not saved in full; rather, 2 bytes of the IP address are masked for anonymisation purposes (e.g.: 192.168.xxx.xxx). This makes it no longer possible to assign the shortened IP address to the individual computer. When you visit our website, the following data in particular is stored:
Purpose of the processing: the processing of users’ personal data enables us to analyse the browsing behaviour of our users. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continually improve our website and make it more user-friendly.
We also use the Heatmap module. The Heatmap service from Matomo shows us the areas of our website where the user’s mouse is most frequently moved or clicked.
The user data we store via Matomo will not be passed on to third parties.
The legal basis for the processing of users’ personal data is essentially the user’s consent in accordance with Art. 6 Para. 1 S. 1(a) GDPR. You may revoke this consent at any time with future effect.
You can find further information on Matomo’s terms of service and data protection regulations at: https://matomo.org/privacy/
Our website uses analysis services provided by Piwik PRO, Piwik PRO GmbH (hereinafter termed ‘Piwik’), Kurfürstendamm 21, 10719 Berlin, Germany. This involves setting statistics cookies, which we can use to analyse your user behaviour, among other things.
Using Piwik PRO, we interpret information on your visits to our website (e.g. sequence of subpages accessed, dwell time on these subpages) for the purposes of analysis in order to understand how visitors use our website.
The purpose is to analyse the click behaviour of visitors to our website so that we can generate statistics about the use of our website. This allows us to improve our website and adapt it to your needs. Data that is generated when you visit this website is also processed:
The legal basis is your consent Art. 6 Para. 1 S. 1(a), Art. 7 GDPR, where you have accepted all cookies or the statistical cookies in the cookie banner. The transmission of this data is voluntary and not required for the conclusion of an agreement.
We store the data gathered by Piwik PRO for a maximum of 12 months. The period of validity of the individual cookies can be found in the cookie overview.
Your consent to the use of the analysis service can be revoked at any time with future effect via the cookie banner by rejecting the use of statistical cookies or all cookies. If you use several devices or browsers, you must revoke this consent for each individual device in each individual browser.
We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and its representative in the Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter termed Google). Among other things, Google Analytics checks where visitors are based, the amount of time they spend on individual pages, and the use of search engines. This allows better monitoring of the success of advertising campaigns. To do this, Google places a cookie on your computer. The cookie allows personal data to be stored and evaluated, especially the user’s activity (in particular, which pages have been visited and which elements have been clicked on); device and browser information (in particular the IP address and operating system); data about the advertisements shown (in particular, which advertisements were displayed and whether the user clicked on them); and also data from advertising partners (in particular pseudonymised user IDs).
We use Google Analytics (Universal Analytics) to evaluate your use of our website, to compile reports on your activities and to use other Google services related to the use of our website and internet usage.
We have stipulated that IP addresses be anonymised, whereby Google shortens your IP address as soon as technically possible. However, we cannot rule out that your data may be transmitted to the servers of Google LLC based in the USA.
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the activities carried out on the site, and to provide other services related to the use of the website and internet usage to the operator of the website.
You can find further information on data processing carried out by Google here:
The use of Google Analytics (Universal Analytics) enables us to evaluate the use of our website and to target advertising to people who have already expressed an initial interest by visiting the site.
The legal basis for the processing of users’ personal data is essentially the user’s consent in accordance with Art. 6 Para. 1 S. 1(a) GDPR.
Your personal information will be stored for as long as is necessary to fulfil the purposes described in this privacy policy or until you exercise your right of withdrawal.
You have the right to revoke your declaration of consent at any time under data protection law. The revocation of consent does not affect the legality of the processing carried out on the basis of consent up to the point of revocation.
You can prevent Google from collecting and processing your personal data by disabling the storage of third-party cookies on your computer, using the ‘Do not track’ function on a supporting browser, deactivating the execution of script code in your browser, or installing a script blocker like NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
You can also prevent Google from both collecting the data generated by the cookie and that related to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?
With the following link, you can deactivate the use of your personal data by Google: https://adssettings.google.de
You can find further information on objection and removal options in relation to Google at: https://policies.google.com/privacy?
Your personal data will also be transmitted to the USA. The USA has no adequacy decision in accordance with Art. 45 Para. 3 GDPR. We would like to point out that data transmission without the existence of an adequacy decision involves certain risks, which we must inform you about below:
US intelligence services use certain online identifiers (such as IP addresses or unique identifiers) as a starting point for tracking individuals. In particular, we cannot rule out the possibility that these intelligence services may have already collected information about you, by means of which the data transmitted here could be traced back to you.
Providers of electronic communications services headquartered in the USA are subject to surveillance by US intelligence agencies in accordance with 50 U.S. Code § 1881a (‘FISA 702’). In accordance with 50 U.S. Code § 1881a, providers of electronic communications services headquartered in the USA have an obligation to provide the US authorities with personal data, without you being entitled to any potential means of redress. Even encrypting the data in the electronic communications service provider’s data centres cannot provide adequate protection, since an electronic communications service provider has a direct obligation, with respect to the imported data in its possession, custody or control, to allow access to or to release the data. This obligation can expressly also extend to the cryptographic keys, without which the data cannot be read.
The fact that this is not just a ‘theoretical danger’ is shown by the judgement of the ECJ on 16 July 2020 (Rs. C 311/18, ‘Schrems II’).
We have concluded guarantees with Google in the form of standard data protection clauses in accordance with Art. 46 Para. 2(c) GDPR. You can request a copy of the standard data protection clauses from us.
Our website uses Google Ads Conversion Tracking, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”), to record the use of our website for statistical reasons and evaluate it for the purpose of optimising our products and services for you. Google Ads sets a cookie on your computer if you are directed to our website via a Google ad.
These cookies cease to be valid after 30 days. If a user visits specific pages of the Ads customer’s website and the cookie remains active, the cookie allows Google and the customer to recognise that the user clicked on the advertisement and was directed to this website.
The information generated by cookies about your use of this website is transferred to a Google server in the US and stored there. We have concluded a data processing agreement with Google for the use of Google Ads. This agreement serves to ensure that Google processes the data in compliance with the EU General Data Protection Regulation and to guarantee the rights of data subjects. Part of the order processing contract with Google are so-called EU standard data protection clauses (Art. 46 Para. 2 S. 1(c) GDPR). These are classed as an appropriate guarantee to protect the transfer and processing of personal data outside the EU.
Each Ads customer receives a different cookie. This means that cookies cannot be tracked across different Ads customers’ websites. The information collected using the conversion cookie serves to create conversion statistics for Ads customers that have opted to use conversion tracking. This enables Google to determine the total number of users who have clicked on our ad and were directed to a website equipped with a conversion tracking tag. However, we do not receive any information that can be used to personally identify users.
You can find Google’s privacy policy for conversion tracking here.
The legal basis for setting cookies and processing your data is your consent. You can revoke your consent at any time with future effect. This does not affect the lawfulness of the processing up to the time of revocation.
You can prevent participation in this tracking as follows: by disabling interest-based ads from providers that are part of the self-governing About Ads campaign via the link https://optout.aboutads.info/. These settings are reset when you erase your cookies.
We use advanced conversions from Google Ads from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter termed ‘Google’). Advanced conversions allow conversions to be tracked more accurately. The existing conversion tags are supplemented using this feature. It enables us to send our conversion data as hash values from our website to Google. For this purpose, the secure SHA256 one-way hash algorithm is applied to customer data (e.g. email addresses) before it is sent to Google. The hash data is then matched to signed-in Google accounts in order to assign the conversions from our campaigns to users’ actions, such as clicks or views, in response to adverts.
You can find the customer data guidelines regarding advanced conversions here. How Google uses your data is described here.
The legal basis for setting cookies and processing your data is your consent. You can revoke your consent at any time with future effect. This does not affect the lawfulness of the processing up to the time of revocation.
Your personal data will be stored for as long as is necessary to fulfil the purposes described in this privacy policy or as required by law.
Further information on your rights to objection and erasure with regard to Google can be found at: https://policies.google.com/privacy
Our website uses services provided by YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to embed videos on the website. You may need to click a button on the playback screen and accept cookies to play the video. If you press play on a video on the website, your IP address is sent to YouTube and cookies are installed on your computer before the video is actually played. However, we have embedded our YouTube videos with enhanced privacy mode (in this case, YouTube still contacts the Google Marketing Platform service, but according to Google’s privacy policy, personal data is not analysed in this process). As a result, YouTube no longer stores information about visitors unless they watch the video. When you click on the video, your IP address is sent to YouTube and YouTube recognises that you have watched the video. If you are logged in to YouTube, this information is also linked to your user account (you can prevent this by logging out of YouTube before viewing the video).
We have no knowledge or influence on the possible collection and use of your data by YouTube at that point. For more detailed information, please refer to YouTube’s privacy policy at https://policies.google.com/privacy. In addition, please refer to our general description in this Privacy Notice with respect to the general handling of cookies and disabling them.
If you consent to this in advance, we use the Custom Audiences remarketing feature offered by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook Ireland”) on our websites. This feature allows us to direct targeted advertising at website visitors by placing personalised, interest-based Facebook ads tailored to visitors of the website when you visit the Facebook social network. To make use of the various features available, we have agreed terms and conditions with Facebook as part of a data processing agreement as per Article 28 GDPR. In this agreement, Facebook affirms that it processes data in accordance with the GDPR and that it protects the rights of data subjects. The legal basis for setting cookies and processing your data is your consent. You can revoke your consent at any time with future effect. This does not affect the lawfulness of the processing up to the time of revocation.
You may revoke your consent to the use of the global Custom Audiences service here on the Facebook website. After logging in to your Facebook account, you will be taken to the settings page for Facebook Ads.
The Facebook pixel allows us to use tracking solutions and analytics services to see how you react to our ads on Facebook, for example when you click on a link in the ad that leads to our website. This gives us a better overview of how successful our campaigns on Facebook are and helps us continually optimise them. We also use the pixel to identify you as a visitor to our website. We can use this information to display the ads we post on Facebook only to those Facebook users who are also likely to be interested in our products and services, either because they have visited our website before or because they have certain characteristics (e.g. interested in certain topics or products identified based on the websites they have visited).
The pixel is loaded when you visit our website or respond to an ad we have placed on Facebook, for example by clicking on a link to our website contained in the ad. This creates a pixel ID, which is stored in a cookie, so that we then receive an analysis of your user behaviour. The pixel does not enable us to identify you personally.
The legal basis for setting pixels and processing your data is your consent. You can revoke your consent at any time with future effect. This does not affect the lawfulness of the processing up to the time of revocation.
We currently use the following social media buttons: Facebook, Twitter and Xing. We use the Shariff tool developed by c’t. This means that when you visit our site, no personal data is initially disclosed to the button providers. Communication with social networks is done by a script stored on the server, which acts as an intermediary between the social network and the user. Users are only directly connected to Facebook, Twitter or Xing when they become active. Social networks cannot collect data about users before they are active. The button provider is recognisable by logo or initial shown in the box. You can communicate directly with the social network provider by clicking the button. Only by clicking the button will the social network receive the information that you have accessed the relevant website. In the case of Facebook, the IP address is anonymised immediately after it has been collected according to the providers in Germany. By using the button, your personal data is transmitted to the social network provider in question and stored there (in the case of US providers, in the US). Since the provider collects data in particular using cookies, we recommend that you adjust your browser’s security settings to erase all cookies before clicking on the button.
We have no influence on the data collected and any data processing procedures, nor are we aware of the full extent of data collection, the purposes of processing, or the retention periods. Furthermore, we do not have any information about the erasure of the data collected by the button provider.
The button provider stores the data collected about you as user profiles and uses them for the purposes of advertising, market research and/or to tailor the design of its website. In particular, this kind of analysis is conducted (including for users who are not logged in) for the purpose of tailoring advertising to the needs of users and to inform other social network users about your activity on our website. You have a right to object to the creation of these user profiles. To exercise this right, please contact the button provider in question. The buttons allow us to offer your the option to interact with social networks and other users to help us optimise our website and tailor it to the interests of our users. The legal basis for the use of these buttons is Article 6 Paragraph 1 Sentence 1(a) GDPR.
The data is disclosed regardless of whether you have an account with the button provider and are logged in there. If you are logged in with the button provider, your data we collect is directly linked to your existing account with the button provider. For example, if you press the activated button and link to the website, the button provider also stores this information in your user account and publicly shares it with your contacts. We recommend regularly logging out after using a social network. However, this is particularly recommended before clicking a button since this prevents the information from being linked to your profile with the plugin provider.
More information on the purpose and extent of data collection and processing by these button providers is available in each button provider’s privacy notice as listed below. The links below also provide additional information about your rights in this regard, as well as options for adjusting your settings to protect your privacy.
Button provider addresses and URLs for their privacy notices:
Our website uses the LinkedIn Insights tag, operated by LinkedIn Co., 2029 Stierlin Court, Mountain View, CA 94943, USA (“LinkedIn”). The LinkedIn Insights tag allows us to collect information, including personal data, about visitors to our website. This enables us to track advertising effectiveness and display interest-based ads. The data collected includes the following: URL, referrer URL, IP address, device and browser properties (user agent) and a time stamp. IP addresses are stored only in an abbreviated form or hashed. If you are logged in to LinkedIn during your visit to our website, this information is also collected. The data collected is pseudonymised within seven (7) days, i.e. all personal identifiers are removed. These pseudonymised data remaining is then be erased within 180 days. A data processing agreement has been concluded with LinkedIn. In connection with the use of the LinkedIn Insights tag, data is transmitted to servers in the US. The legal basis for processing is Article 6 Paragraph 1(a) GDPR. Our legitimate interest is in tailoring the design of our website to users’ needs and the opportunity to offer interest-based ads. The interests of the website visitors are sufficiently taken into account through the measures envisaged by LinkedIn, in particular prompt pseudonymisation. We therefore do not assume any overriding interest that precludes our legitimate interest. LinkedIn’s privacy policy is available here: https://www.linkedin.com/legal/privacy-policy.
Our website uses the Corazon powered by questFon call tracking service (“Corazon”). The processing company is telequest & Internet Solutions GmbH, Liebenauer Hauptstrasse 2–6, 8041 Graz, Austria (“Telequest”).
Corazon incorporates telephone numbers on our website that enable us to further analyse the telephone behaviour of visitors to our website We retain full control over the data collected.
Provided a call is made to us, the following data is collected
We also link this data with the corresponding address data record (hereinafter referred to as “telephone tracking”) if possible based on the available customer data. The data collected is erased no more than six (6) months after it is collected.
We base the use of Corazon on your consent pursuant to Article 6 Paragraph 1(a) GDPR.
Telequest processes the data on our behalf. We have concluded a data processing agreement with Telequest. This agreement serves to ensure that Telequest processes the data in compliance with the EU General Data Protection Regulation and to guarantee the rights of data subjects.More information is available in Telequest’s Data Protection Policy: https://www.telequest.com/datenschutz.
Our websites use Userlike, a live chat software run by Userlike UG. Userlike uses cookies – text files stored on your computer that enable you to conduct real-time one-on-one chats on your website. A data processing agreement has been concluded with Userlike. The data collected is not used to personally identify website visitors, nor is any personally identifiable data linked to the user’s anonymous profile. Userlike UG’s privacy policy is available here.
We use solutions provided by edudip GmbH, Jülicher Strasse 306, 52070 Aachen, Germany (“edudip”) to hold online informational events. In order to participate, it is necessary to provide the data shown on the registration form. For a possible consultation, your zip code will be recorded so that we can assign the appropriate WBS location. To ensure that you do not miss the event you have booked, we will send you brief reminders in advance from time to time. The legal basis for processing is Article 6 Paragraph 1(b) GDPR, i.e. a contractual relationship (in exchange for payment or free of charge) between you and us, as well as Article 6 Paragraph 1 Sentence 1(f) GDPR. Ensuring our events can be properly held is a legitimate interest under the provision mentioned above. We have concluded a data processing agreement with edudip. This means that edudip processes both the data you provide and any data generated in holding the webinar. edudip does this only on our behalf and only in accordance with our instructions. edudip GmbH’s privacy policy is available here: https://www.edudip.com/en/privacy. Their policy also includes information about what data is generated when a webinar is held.
When you use our website, you have the option to search for specific products or services. A search function is provided on our website for this purpose. To improve search results and display only those results that match your search query, we use the FACT-Finder service provided by Omikron Data Quality GmbH, Habermehlstrasse 17, 75172 Pforzheim, Germany (“Omikron”). Your searches as well as your device’s IP address are transmitted to Omikron and stored for the duration of the session. This is solely to ensure and improve the functionality of your search query. It is not possible for us to identify you with this information. Your data is exclusively processed in Germany. The legal basis for processing is Article 6 Paragraph 1(f) GDPR. Optimising our website’s search feature is a legitimate interest as defined by the provision mentioned above.
More information is available at www.fact-finder.com/gdpr and www.fact-finder.com/privacy-policy.html.
To understand how our customers found their way to our website, we use your browser’s local storage on the device you use to visit our website. We have commissioned a specialist service provider based in Switzerland for this purpose on the basis of a data processing agreement. The information retained in local storage is sent to us by eTermin when you use the form to book a consultancy appointment. This helps us to statistically analyse our presence on third-party websites, e.g. on search engines. The legal basis is your consent as defined by Article 6 Paragraph 1(a) GDPR, which you provide by enabling the “Statistics” category on the cookie banner. You may revoke your consent at any time by adjusting the settings shown above. The information in local storage does not expire. Third parties have no access to this information.
Our website features a video consultation service. We use a tool made by Auvious ltd. to carry out these consultations. More information about the provider is available at https://www.auvious.com. We have concluded a data processing agreement with Auvious ltd. as per Article 28 Paragraph 3 GDPR, which ensures compliance with statutory data protection standards and ensures data is processed securely. The legal basis for processing this data is Article 6 Paragraph 1(b) GDPR (consent to process data at the request of the data subject as needed prior to entering into a contract).
When you use our video consultation tool, the following personal data may be processed: your user ID, user role, IP address, user email (optional), language (optional), meeting date, meeting rating (optional), audio and/or video recordings (optional), screenshots (optional). This data will not be stored any longer than necessary to complete these pre-contractual measures.
WBS holds competitions from time to time. Details are available in the terms and conditions for participation for each competition. When you participate in one of our competitions, we process the data you provide. Generally, this involves an individual competition post (e.g. a comment or photo), your name and your contact details so we can hold the competition and notify you if you win. The legal basis for this is your consent pursuant to Article 6 Paragraph 1(a) GDPR. If you have separately granted us consent to do so, we will include your contact details in our newsletter mailing to keep you informed about current WBS offers and services. You may revoke your consent to your data being processed as described above at any time with future effect, free of charge, by sending a brief message to the contact details provided in Section 1. Revoking your consent does not affect the legality of the processing carried out before your consent was revoked. Beyond revocation, participant data is erased from our active systems once the competition has been completed. Winner data is archived on the basis of Article 6 Paragraph 1(c) GDPR for the duration of our legal retention obligations for reasons relating to commercial and tax law (generally ten (10) years).
WBS may need to amend this Privacy Notice from time to time. We therefore recommend that you read through this Privacy Notice at regular intervals. However, rest assured that amendments will not come into force with retroactive effect and that we will not change the way we handle data previously collected.
Updated on July 30, 2024
Weiskopffstraße 16/17
12459 Berlin
Germany
