Privacy Policy

GfW Gesellschaft für Weiterbildung mbH
(hereinafter referred to as "GfW" or "we") operates an educational holding with the associated website accessible on the Internet at www.gfw.education and its corresponding subdirectories (hereinafter the "Website").

GfW would like to explain in this privacy policy which data is processed and in what form: during your visit to our Website and when contacting us via the contact form. At the same time, we thereby fulfill our information obligation pursuant to Art. 13 of the General Data Protection Regulation (GDPR) towards you.

I. Responsible party and contact details of the Data Protection Officer

The data controller responsible for data processing carried out at our school and on our Website is:

GfW Gesellschaft für Weiterbildung mbH
Phone: +49 30 609541491
Email: contact@gfw.education

II. Personal data, purposes, and legal basis of data processing

1. Personal data

According to the GDPR, personal data means "any information relating to an identified or identifiable natural person (hereinafter referred to as 'data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person."

a) General use of the Website

We do not collect or store any personal data during your visit to our Website.

Notwithstanding the above, the web server of our hosting provider automatically registers access to the Websites, including your IP address.

Additionally, our host creates so-called log files to maintain system security. These log files contain the following information:

Date of access
URL
Contents accessed
Transferred information
Your IP address

This information remains anonymous to us. Therefore, it is not possible to trace it back to an individual.

The processing of your IP address during connection establishment is necessary to provide you with our Website. The subsequent storage is to ensure the security and integrity of our systems. These processing activities are based on Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in the stated purpose.

b) Contact form

We offer you the possibility to contact us via a form. For this purpose, you must provide us with your email address so that we can respond to your inquiry. Additionally, you may provide your name, a subject, and the specific message.

If you contact us via the email address provided on our Website, you provide at least your email address and, if applicable, further information disclosed in your email. To handle your request, we need to process these data.

2. Purposes and legal basis of data processing

The processing of your IP address during connection establishment serves to provide you with our Website and is based on Art. 6 para. 1 lit. f) GDPR. Our legitimate interest is the stated purpose.

The processing in the context of contacting us serves to handle and answer your inquiry. The legal basis is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in this purpose.

If we process data due to our accounting and tax storage obligations, this is based on Art. 6 para. 1 lit. c) GDPR in conjunction with § 257 HGB and § 147 AO.

III. Recipients of data

Within our company, only the departments responsible for processing your requests have access to your data. We also use external service providers where we cannot or do not want to perform services ourselves. These external providers mainly include IT and telecommunications service providers.

Some of these service providers, which we use to communicate with you and process your inquiries, are based in the USA and process personal data there. However, these providers are either certified under the EU-US Privacy Shield, ensuring an adequate level of data protection, or we have concluded appropriate guarantees in the form of Standard Contractual Clauses of the European Commission with them. Templates of these Standard Contractual Clauses are available on the European Commission’s website.

We only transfer data to third countries if it is necessary for the execution of your orders, legally required, or if you have given us your consent.

IV. Storage duration

Our log files are stored for 14 days. Your emails and contact inquiries are stored as long as necessary to process your request and then for a period of 3 years in case you contact us again regarding your original question.

We are subject to statutory retention obligations for documents from tax law, which may contain personal data. Their retention period is governed by § 257 Commercial Code (HGB) and § 147 Tax Code (AO). According to this:

Books and records, inventories, annual financial statements, individual financial statements pursuant to § 325 para. 2a HGB, consolidated financial statements, management reports, consolidated management reports, the opening balance sheet and the working instructions and other organizational documents necessary for their understanding, as well as booking vouchers and documents for bookings in the books required to be kept under § 238 para. 1 HGB, and documents pursuant to Article 15 para. 1 and Article 163 of the Union Customs Code must be retained for 10 years.
Received commercial or business letters, copies of sent commercial or business letters, and other documents relevant for taxation must be retained for 6 years.

The retention period begins at the end of the calendar year in which the last entry was made, the inventory, opening balance sheet, annual financial statement, or management report was prepared, the business letter was received or sent, or the booking voucher was created. After the retention period, the documents are destroyed.

V. Obligation to provide data

You are under no contractual or legal obligation to provide us with personal data. However, without the data you provide, we cannot offer our services.

VI. Existence of automated decision-making (including profiling)

We do not use automated decision-making that has legal effects concerning you or significantly affects you.

VII. Internet-specific data processing

a) Cookies

Our Website uses cookies. These are small files stored on your device and saved in your browser. Cookies serve to improve our offer in terms of user-friendliness, security, and effectiveness and to recognize your browser on your next visit.

You can delete cookies and set your browser to inform you about cookie use. You can also specify when to accept cookies. If you disable cookies, the use of the Website may be limited.

b) Google Analytics

The Website uses Google Analytics, a web analytics service by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. Google Analytics uses cookies—small text files stored in your browser—which enable the analysis of your use of our Website. The information collected via the cookies about your use of the Website is transmitted to a Google server in the USA and stored there.

IP anonymization

Through the IP anonymization feature enabled on our Website, your IP address is shortened before transmission to a Google server in the USA. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google uses the information on our behalf to analyze your Website usage, compile reports on Website activity, and provide related services to the Website operator. Your IP address transmitted via Google Analytics is not merged with other Google data. Other data collected are deleted after 26 months.

The legal basis is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in the stated purpose.

Demographic features

Our Website uses the "demographic features" function of Google Analytics. This allows reports with information on the age, gender, and interests of Website visitors. These data come from interest-based advertising by Google and visitor data from third parties. These data cannot be assigned to a specific person. You can disable this feature at any time in your Google account's ad settings.

d) Adroll

Our Website uses Adroll, a retargeting service. Adroll also uses cookies stored in your browser during your visit. This creates a list of visitors and allows Adroll to show you GfW advertising even when you visit other websites or social media.

VIII. Data subject rights

The GDPR guarantees you certain rights which you can assert against us—if the legal requirements are met:

Art. 15 GDPR – Right of access: You have the right to request confirmation from us whether personal data concerning you is processed and, if so, which data and the details of the processing.
Art. 16 GDPR – Right to rectification: You have the right to request correction of incorrect personal data concerning you. You may also request the completion of incomplete personal data, including by a supplementary statement.
Art. 17 GDPR – Right to erasure: You have the right to demand the immediate deletion of personal data concerning you.
Art. 18 GDPR – Right to restriction of processing: You have the right to request the restriction of processing.
Art. 20 GDPR – Right to data portability: If processing is based on consent or contract, you have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format and transmit it to another controller.
Art. 21 GDPR – Right to object: For reasons arising from your particular situation, you can object at any time to the processing of your personal data based on our legitimate interest or public interest. Upon objection, we will no longer process your data unless we have overriding legitimate grounds or the processing serves legal claims. If your data is processed for direct marketing, you have the right to object at any time, and we will cease processing for these purposes.
Art. 77 GDPR in conjunction with § 19 BDSG – Right to lodge a complaint: You can lodge a complaint with a supervisory authority, particularly in your place of residence, work, or the place of the alleged infringement, if you believe the processing of your data violates applicable law.

IX. Questions or comments

We take all conceivable precautions to protect and secure your data. Your questions and comments regarding data protection are welcome—just send an email to bewerbungen@gfw.education.

Berlin, January 2022