Privacy Policy

1. Introduction

In the following, we inform about the processing of personal data when using

our website https://www.elevel-academy.de/
of our profiles in social media.
Personal data is any data that can be related to a specific natural person, e.g.
their name or IP address.

1.1. Contact details

The responsible person according to Art. 4 para. 7 EU General DataProtection Regulation (DSGVO) is Daniel Firgau, Tobias Kruse & MaxMiddelhauve GbR, Seidentraße 57, 70174 Stuttgart, Germany, e-mail: info@elevel- academy.de. We are legally represented by Tobias Kruse &Max Middelhauve.

Our data protection officer is the:

heyData GmbH
Kantstr. 99, 10627 Berlinwww.heydata.eu
Email: datenschutz@heydata.eu.

1.2. Scope of data processing, processing purposes and legalbases

We detail the scope of data processing, processing purposes and legal basesbelow. The following are generally considered to be the legal basis for dataprocessing:

Art. 6 para. 1 p. 1 it. a DSGVO serves as our legal basis forprocessing operations for which we obtain consent.
Art. 6 para. 1 p. 1 lit. b DSGVO is the legal basis, insofar as theprocessing of personal data is necessary for the performance of acontract is necessary, e.g. when a site visitor purchases a product from us or weperform a service for him. This legal basis also applies to processingthat is necessary for pre-contractual measures, such as inquiries aboutour products or services.

Art. 6 (1) p. 1 lit. c DSGVO applies if we fulfill a legal obligation withthe processing of personal data, as may be the case, for example, intax law.
Art. 6 (1) p. 1 lit. f DSGVO serves as the legal basis when we caninvoke legitimate interests to process personal data, e.g. for cookiesthat are necessary for the technical operation of our website.
1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside ofthe EEA, the security of the data during the transfer is guaranteed, insofar as(e.g. for the UK, Canada and Israel) available, by adequacy decisions of theEU Commission (Art. 45 Ab. 3 DSGVO).

If no adequacy decision exists (e.g., for the USA), the legal basis for the datatransfer is usually, i.e., unless we indicate otherwise, standard contractualclauses. These are a set of rules adopted by the EU Commission and arepart of the contract with the respective third party. According to Art. 46 (2) lit.b DSGVO, they ensure the security of the data transfer. Many of theproviders have given contractual guarantees that protect the data beyond thestandard contractual clauses. These are

e.g. guarantees regarding the encryption of data or regarding an obligationof the third party to notify data subjects when law enforcement bodies wantto access data.

1.4. Storage duration

Unless expressly stated within the scope of this data protection declaration,the data stored by us will be deleted as soon as it is no longer required for itsintended purpose and the deletion does not conflict with any statutoryretention obligations. If the data is not deleted because it is required for otherand legally permissible purposes, its processing will be restricted, i.e. thedata will be blocked and not processed for other purposes. This applies, for example, todata that we must retain for reasons of commercial or tax law.

1.5. Rights of the data subjects

Data subjects have the following rights vis-à-vis us with regard to the personaldata concerning them:

Right to information,
Right to rectification or deletion,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Right to revoke consent given at any time.
Data subjects also have the right to complain to a data protectionsupervisory authority about the processing of their personal data. Contactdetails for the data protection supervisory authorities are available athttps://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

In the context of a business relationship or other relationship, customers,interested parties or third parties only have to provide us with the personaldata that is required for the establishment, implementation and termination ofthe business relationship or for the other relationship, or which we are legallyobliged to collect. Without this data, we will usually have to refuse toconclude a contract or provide a service or will no longer be able to performan existing contract or other relationship.

Mandatory information is marked as such.

1.7. No automatic decision making in individual cases For the establishment and implementation of a business relationship or otherrelationship, we generally do not use fully automated decision-makingpursuant to Article 22 DSGVO. Should we use these procedures in individualcases, we will inform about this separately if this is required by law.

1.8. Contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g.names and e-mail addresses) will be stored by us in order to answerquestions. The legal basis for the processing is our legitimate interest (Art. 6para. 1 p. 1 lit. f DSGVO) to answer inquiries directed to us. We delete thedata accruing in this context after the storage is no longer necessary orrestrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customersand their wishes better. In doing so, we collect the data requested in eachcase. It is our legitimate interest to get to know our customers and their wishesbetter, so that the legal basis for the associated data processing is Art. 6 para.1 p. 1 lit f DSGVO. We delete the data when the results of the surveys havebeen evaluated.

2. Newsletter

We reserve the right to inform customers who have already used servicesfrom us or purchased goods from time to time by e-mail or other meanselectronically about our offers, if they have not objected to this. The legalbasis for this data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Ourlegitimate interest lies in direct advertising (recital 47 DSGVO). Customerscan object to the use of their e-mail address for advertising purposes at anytime without incurring additional costs, for example via the link at the end ofeach e-mail or by sending an e-mail to our above-mentioned e-mail address. Based on the consent of the recipients (Art. 6 para. 1 p. 1 lit. a DSGVO), wealso measure the opening and click-through rate of our newsletters tounderstand which content is relevant to our recipients.

We send newsletters using the Mailchimp tool from the provider RocketScience Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA30308, USA (privacy policy: https://mailchimp.com/legal/privacy/). Theprovider processes content, usage, meta/communication data and contactdata in the USA.

3. Data processing on our website

3.1. Informational use of the website

During the informational use of the website, i.e. when site visitors do notseparately transmit information to us, we collect the personal data that thebrowser transmits to our server in order to ensure the stability and security ofour website. This is our legitimate interest, so that the legal basis is Art. 6para. 1 p. 1 lit. f DSGVO.

These data are:

IP address
Date and time of the request
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (concrete page)
Access status/HTTP status code
Data volume transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is nolonger necessary, at the latest after 14 days.

3.2. Web hosting and provision of the website

Our website hosts Webflow. The provider is Webflow, Inc., 398 11th St.,Floor 2, San Francisco, CA 94103, USA. In doing so, the provider processesthe personal data transmitted via the website, e.g. content, usage,meta/communication data or contact data, in the USA. Further informationcan be found in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

It is our legitimate interest to provide a website, so that the legal basis of thedescribed data processing is Art. 6 para. 1
S. 1 lit. f DSGVO is.

We use the Cloudflare content delivery network for our website. The provideris Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA. Theprovider thereby processes the personal data transmitted via the website, e.g.content, usage, meta/communication or contact data in the USA. For moreinformation, please refer to the provider's privacy policy athttps://www.cloudflare.com/de-de/ privacypolicy/.

We have a legitimate interest in using sufficient storage and deliverycapacities to ensure optimal data throughput even during large load peaks.The legal basis of the described data processing is therefore Art. 6 para. 1 p. 1lit. f GDPR.

Standard data protection clauses guaranteed (Art. 46 para. 2 lit. c DSGVO),which we have agreed with the provider.

3.3. Contact form

When contacting us via the contact form on our website, we store the datarequested there and the content of the message. The legal basis for theprocessing is our legitimate interest in answering inquiries directed to us. Thelegal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.

We delete the data accruing in this context after the storage is no longerrequired or restrict the processing if there are legal retention obligations.

3.4. Job ads

We post jobs that are available within our company on our website, on siteslinked to the website, or on third-party websites.
The processing of the data provided as part of the application is carried outfor the purpose of implementing the application process. Insofar as this isnecessary for our decision to establish an employment relationship, the legalbasis is Art. 88 (1) DSGVO in conjunction with Section 26 (1) BDSG. Wehave marked the data required to carry out the application processaccordingly or refer to them. If applicants do not provide this data, we cannotprocess the application.

Further data is voluntary and not required for an application. If applicantsprovide further information, this is based on their consent (Art. 6 para. 1 p. 1lit. a DSGVO).

We ask applicants to refrain from providing information on political opinions,religious beliefs and similarly sensitive data in their resumes and coverletters. They are not required for an application. If applicants neverthelessprovide such information, we cannot prevent their processing as part of theprocessing of the resume or cover letter. Their processing is then also basedon the consent of the applicants (Art. 9 (2) a DSGVO).

Finally, we process the applicants' data for further application procedures ifthey have given us their consent to do so. In this case, the legal basis is Art. 6para. 1 p. 1 lit. a DSGVO.

We pass on the applicants' data to the responsible employees in the HRdepartment, to our order processors in the area of recruiting and to theemployees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following theapplication process, we delete the data only after the employment relationshiphas ended. Otherwise, we delete the data no later than six months afterrejecting an applicant.

If applicants have given us their consent to also use their data for furtherapplication procedures, we will not delete their data until one year afterreceipt of the application.

3.5. Offer goods

We offer goods via our website. In the process, we process the following datain the context of the order:

E-mail address
Payment information
Billing address
The processing of the data takes place for the performance of the contractconcluded with the respective site visitor (Art. 6 para. 1 p. 1 lit. b DSGVO).

3.6. Payment service provider

For the processing of payments, we use payment processors who arethemselves data controllers within the meaning of Art. 4 No. 7 DSGVO. Insofaras they receive data and payment data entered by us in the ordering process,we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 p. 1lit. b DSGVO).

These payment service providers are:

PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg
Stripe Payments Europe, Ltd, Ireland

3.7. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in theweb browser on the end device of a site visitor. Cookies help to make theoffer more user-friendly, effective and secure. Insofar as these cookies arenecessary for the operation of our website or its functions (hereinafter"technically necessary cookies"), the legal basis for the associated dataprocessing is Art. 6 para. 1

S. 1 lit. f DSGVO. We have a legitimate interest in providing customers andother site visitors with a functional website. Specifically, we set technicallynecessary cookies for the following purpose or purposes:

Cookies that store the shopping cart,
Cookies that payment providers set for payment processing and do
not analyze user behavior and

Flash cookies set to play media content
3.8. Conducting seminars and forwarding your data to partnercompanies

When you register for a free webinar on our website, we first process yourregistration data to manage your registration and provide the access data.The legal basis for data processing is Art. 6 (1) lit. b DSGVO. Furthermore,we use your email address to inform you about further webinars and events.The legal basis for this data processing is your consent according to Art. 6para. 1 lit. a DSGVO.

As part of your registration, we will forward the contact information providedduring registration (name, phone number, and professional status provided)to one of our partner companies who will
you can view here. Our partner companies use this information to obtainfeedback on the respective webinar and to present their own services. Theuse is based on consent in accordance with Art. 6 para. 1 lit. a DSGVO.

If you revoke your advertising consent to ELEVEL, we will also notify thepartner companies involved of this revocation.
In addition, you as the affected party can also contact therespective partner company individually.

3.9. Third-party supplier

3.9.1. Google Tag Manager

We use Google Tag Manager for analysis and advertising. The provider isGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Theprovider processes usage data (e.g. websites visited, interest in content,access times) in the USA.

We delete the data when the purpose for collecting it no longer applies.Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en.

3.9.2. Zapier

We use Zapier for automation between applications. The provider isZapier, Inc, 548 Market St. #62411, San Francisco, CA 94104-5401,USA. The provider processes usage data (e.g. web pages visited, interestin content, access times) and meta-/
communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We havea legitimate interest in easily connecting the applications in our company andthus optimizing the way we work. The legal basis for the transfer to a country outside the EEA are standardcontractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protectionclauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with theprovider.

We delete the data when the purpose for collecting it no longer applies.Further information is available in the provider's privacy policy at https://zapier.com/privacy.

3.9.3. Webflow

We use Webflow to create websites. The provider is Webflow, Inc., 39811th St., Floor 2, San Francisco, CA 94103, USA. The provider processesusage data (e.g. websites visited, interest in content, access times) andmeta/communication data (e.g. device information, IP addresses) in theUSA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We havea legitimate interest in setting up and maintaining a website and thuspresenting ourselves to the outside world.

We delete the data when the purpose for collecting it no longer applies.Further information is available in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

3.9.4. Google Conversion Tag

We use Google Conversion Tag for conversion tracking. The provider isGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Theprovider processes usage data (e.g. websites visited, interest in content,access times) in the USA. The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. Theprocessing is based on consent. Data subjects may revoke their consent atany time by contacting us, for example, using the contact details provided inour privacy policy. The revocation does not affect the lawfulness of theprocessing until the revocation.

The data is deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is available inthe provider's privacy policy at https://policies.google.com/ privacy?hl=enhttps://support.google.com/tagmanager/answer/9323295?hl=en&ref_topic=3441532.

3.9.5. Facebook Conversion API

We use Facebook Conversion API for analysis. The provider is MetaPlatforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin2, Ireland. The provider processes usage data (e.g. websites visited,interest in content, access times) and meta/communication data (e.g. deviceinformation, IP addresses) in the USA.

The legal basis for the transfer to a country outside the EEA are standardcontractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protectionclauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with theprovider. The data is deleted when the purpose of its collection has ceased to apply andthere is no obligation to retain it. Further information is available in theprovider's privacy policy at https://www.facebook.com/ policy.php.

3.9.6. Wistia

We use Wistia for video marketing. The provider is Wistia, Inc., 120 BrooklineStreet, Cambridge, Massachusetts, 02139, USA. The provider processesmeta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have alegitimate interest in making our website particularly lively through videos.

The data is deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is availablein the provider's privacy policy at https://wistia.com/privacy.

3.9.7. HubSpot

We use HubSpot to manage customer relationships. The provider isHubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The providerprocesses usage data (e.g. websites visited, interest in content, accesstimes), content data (e.g. entries in online forms) and meta/communicationdata (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We havea legitimate interest in managing data in a simple and inexpensive way. The legal basis for the transfer to a country outside the EEA is standardcontractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protectionclauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with theprovider.

The data is deleted when the purpose for which it was collected no longerapplies and there are no retention obligations to the contrary. Furtherinformation is available in the provider's privacy policy athttps://legal.hubspot.com/ privacy-policy.

3.9.8. Mailchimp

We use Mailchimp for email marketing and email management. The provideris Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000,Atlanta, GA 30308, USA. The provider processes usage data (e.g. websitesvisited, interest in content, access times), content data (e.g. entries in onlineforms), contact data (e.g. email addresses, telephone numbers) andmeta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the transfer to a country outside the EEA is standardcontractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protectionclauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with theprovider.

3.9.9. Paddle

We use Paddle for payments. The provider is Paddle.com Market Limited, 15Briery Close, Great Oakley, Corby, Northamptonshire, NN18 8JG, UnitedKingdom. The provider processes content data (e.g. entries in online forms),payment data (e.g. bank details, invoices, payment history) andmeta/communication data (e.g. device information, IP addresses) in the UK.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Wehave a legitimate interest in maintaining a structured overview of ourrevenue.

Legal basis of the transfer to a country outside the EEA are adequacydecisions. The security of the data transferred to the third country (i.e. acountry outside the EEA) is ensured because the EU Commission hasdecided, within the framework of an adequacy decision pursuant to Article 45(3) of the GDPR, that the third country offers an adequate level of protection.

The data is deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is availablein the provider's privacy policy at https://paddle.com/privacy/.

3.9.10. Elfsight

We use Elfsight to integrate widgets. The provider is SP Iusupov A.A.. Theprovider processes usage data (e.g. websites visited, interest in content,access times) and meta/communication data (e.g. device information, IPaddresses) .

Legal basis of the transfer to a country outside the EEA are .

The data is deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is availablein the Privacy policy of the provider available at https://elfsight.com/privacy-policy/.

3.9.11. Google Analytics

We use Google Analytics for analysis. The provider is Google IrelandLimited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. Theprovider processes usage data (e.g. websites visited, interest in content,access times) and meta/communication data (e.g. device information, IPaddresses) in the USA.

3.9.12. Typeform

We use Typeform for questionnaires and forms. The provider is TypeformS.L., 163 Carrer de Bac de Roda, Barcelona, Spain. The provider processescontent data (e.g. entries in online forms) and meta/communication data (e.g.device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. Theprocessing is based on consent. Data subjects may revoke their consent atany time by contacting us, for example, using the contact details provided inour privacy policy. The revocation does not affect the lawfulness of theprocessing until the revocation. The legal basis for the transfer to a country outside the EEA is standardcontractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protectionclauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with theprovider.

4. Data processing on social media platforms

We are represented in social media networks in order to present ourcompany and our services there. The operators of these networks regularlyprocess their users' data for advertising purposes. Among other things, theycreate user profiles from their online behavior, which are used, for example,to show advertising on the pages of the networks and elsewhere on theInternet that corresponds to the interests of the users. To this end, theoperators of the networks store information on user behavior in cookies onthe users' computers. Furthermore, it cannot be ruled out that the operatorsmerge this information with other data. Users can obtain further informationand instructions on how to object to processing by the site operators in thedata protection declarations of the respective operators listed below. It is alsopossible that the operators or their servers are located in non-EU countries,so that they process data there. This may result in risks for users, e.g.because it may be more difficult to enforce their rights or becausegovernment agencies may access the data.

When users of the networks contact us via our profiles, we process the dataprovided to us in order to respond to the inquiries. This is our legitimateinterest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

4.1. Facebook

We maintain a profile on Facebook. The operator is Meta Platforms IrelandLtd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Theprivacy policy is available here: https://www.facebook.com/policy.php. One way to object to data processing is via settings for advertisements:https://www.facebook.com/settings? tab=ads.
We are jointly responsible for processing the data of visitors to our profile onthe basis of an agreement within the meaning of Art. 26 DSGVO withFacebook. Facebook explains exactly what data is processed athttps://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise theirrights both against us and against Facebook. However, under our agreementwith Facebook, we are obliged to forward requests to Facebook. Datasubjects will therefore receive a faster response if they contact Facebookdirectly.

4.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacypolicy is available here: https://help.instagram.com/ 519522125107875.

4.3. YouTube

We maintain a profile on YouTube. The operator is Google Ireland LimitedGordon House, Barrow Street Dublin 4. Ireland. The privacy policy is availablehere: https://policies.google.com/privacy?hl=de.

4.4. Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 MarketStreet, Suite 900, San Francisco, CA 94103, USA. The privacy policy isavailable here: https://twitter.com/de/privacy. One way to object to dataprocessing is via the settings for advertisements:https://twitter.com/personalization.

4.5. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland UnlimitedCompany, Wilton Place, Dublin 2, Ireland. The privacy policy is availablehere: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. Apossibility to object to the data processing arises via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. Acurrent version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, pleasefeel free to contact us using the contact information provided above..

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