Privacy Notice

Privacy Notice for our website

1. General Information and Mandatory Information

Data collection on this website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. You can find the contact details of the responsible person in the section "Notice of the Responsible Entity" in this privacy notice.

How do we collect your data?

Your data is collected by us when you provide it to us. This may be data that you enter into a contact form, for example.

Other data is automatically or with your consent collected by our IT systems when you visit the website. These are mainly technical data (such as internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. In addition, under certain circumstances, you have the right to request the restriction of the processing of your personal data.

Furthermore, you have the right to lodge a complaint with the competent supervisory authority. For this and for further questions on the subject of data protection, you can contact us at any time.

Analysis tools and third-party tools

Your browsing behavior can be statistically evaluated when you visit this website. This is mainly done with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy notice.

2. Hosting and Content Delivery Network (CDN)

Hosting with Google Firebase

We use Google Firebase, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, for hosting and providing our website. The use of Firebase can result in the processing of personal data of our users, such as IP addresses, behavioral data, and meta/communication data.

For more information, please see Google Firebase's privacy policy: https://firebase.google.com/support/privacy/.

The use of Google Firebase is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in a reliable presentation of our website. If consent has been requested, the processing will be carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent can be revoked at any time.

Hosting with All-Inkl

We host parts of our website with All-Inkl. The provider is ALL-INKL.COM - Neue Medien Münnich, Inh. René Münnich, Hauptstraße 68, 02742 Friedersdorf (hereinafter: All-Inkl). For more information, please see All-Inkl's privacy policy: https://all-inkl.com/datenschutzinformationen/.

The use of All-Inkl is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in a reliable presentation of our website. If consent has been requested, the processing will be carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent can be revoked at any time.

Video Delivery via Bunny.net

We use Bunny.net for embedding and delivering videos on our platform. The provider is BunnyWay d.o.o., Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia.

When a video is played, connection data (in particular IP address, browser information, and timestamp) is transmitted to Bunny.net servers operated within the EU (data center in Frankfurt, Germany). Bunny.net processes this data to provide the video streaming service.

This is done on the basis of Art. 6(1)(f) GDPR (legitimate interest in efficient and privacy-compliant video delivery). For more information, please see Bunny.net's privacy policy: https://bunny.net/privacy.

Data Processing Agreement

We have entered into a data processing agreement (DPA) with the above-mentioned providers. This is a legally required contract that ensures that these providers process the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General Information and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations and this privacy notice.

If you use this website, various personal data will be collected. Personal data is data that can be used to personally identify you. This privacy notice explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. A complete protection of data against access by third parties is not possible.

Notice of the Responsible Entity

The responsible entity for data processing on this website is:

Tobias Grawinkel (nuuminds)
Driesener Straße 8 B
D-10439 Berlin

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage Period

Unless a more specific storage period has been mentioned in this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial retention periods); in the latter case, the deletion will take place after these reasons cease to exist.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke a consent already given at any time. The lawfulness of data processing that has taken place up to the revocation remains unaffected by the revocation.

Right to object to data collection in special cases as well as to direct advertising (Art. 21 GDPR)

If data processing is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR, you have the right at any time to object to the processing of your personal data for reasons arising from your particular situation; this also applies to profiling based on these provisions. You can find the respective legal basis on which processing is based in this privacy notice. If you object, we will no longer process your affected personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims (objection under Art. 21 para. 1 GDPR).

If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct advertising. If you object, your personal data will subsequently no longer be used for the purpose of direct advertising (objection under Art. 21 para. 2 GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged violation. The right to lodge a complaint is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a standard, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done if it is technically feasible.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, deletion, and correction

Under the applicable legal provisions, you have the right to obtain free-of-charge information about your stored personal data, its origin and recipients, and the purpose of data processing, and if applicable, the right to correct or delete such data. For this purpose, as well as for any questions regarding personal data, you can contact us at any time.

Right to restrict processing

You have the right to request the restriction of processing of your personal data. For this purpose, you can contact us at any time. The right to restrict processing applies in the following cases:

• If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. During the period of verification, you have the right to request the restriction of processing of your personal data.

• If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of deletion.

• If we no longer need your personal data, but you require it for exercising, defending, or claiming legal rights, you have the right to request the restriction of processing of your personal data instead of deletion.

• If you have objected pursuant to Art. 21(1) GDPR, an assessment must be made as to whether your interests override ours. Until it has been determined whose interests prevail, you have the right to request the restriction of processing of your personal data.

If you have restricted the processing of your personal data, such data - apart from being stored - may only be processed with your consent or for the purpose of asserting, exercising, or defending legal claims or protecting the rights of another natural or legal person, or for reasons of important public interest of the European Union or a member state.

Objection to promotional emails

We hereby object to the use of contact data published within the scope of the imprint obligation for the purpose of sending unsolicited advertising and informational material. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited advertising information, such as spam emails.

4. Data collection on this website

Cookies

Our website uses so-called "cookies". Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted after your visit ends. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them.

In some cases, cookies from third-party companies can also be stored on your device when you enter our site (third-party cookies). These allow us or you to use certain services provided by the third-party company (e.g., cookies for payment processing).

Cookies have various functions. Numerous cookies are technically necessary because certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.

Cookies that are necessary for electronic communication processes (necessary cookies) or to provide certain functions requested by you (functional cookies, such as the shopping cart function) or to optimize the website (e.g., cookies to measure website traffic) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies has been requested, the storage of the respective cookies is based exclusively on this consent (Art. 6 para. 1 lit. a GDPR); the consent can be revoked at any time.

You can set your browser to inform you about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be limited.

To the extent that cookies are used by third-party companies or for analysis purposes, we will inform you separately within the scope of this data protection declaration and, if necessary, ask for your consent.

Contact form

If you send us inquiries via the contact form, your information from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We will not share this information without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested.

The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your inquiry has been processed). Mandatory legal provisions - especially retention periods - remain unaffected.

Inquiry by email, telephone or fax

If you contact us by email, telephone or fax, your request including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We will not share this information without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested.

The data you send us through contact requests will remain with us until you request deletion, revoke your consent for storage, or the purpose for data storage no longer applies (e.g. after completion of your request). Mandatory statutory provisions, especially statutory retention periods, remain unaffected.

3. Use of our Platform

User Accounts (B2B Access)

Our platform is exclusively accessible within the scope of existing B2B agreements. Self-registration is not possible. User accounts are created by us on behalf of and under the instruction of the respective customer company. The required master data — typically first and last name and business email address — is provided to us by the customer company.

We process the following personal data in the course of platform use: first and last name, business email address, company / organization, learning progress, issued Certificates of Participation, course / session participation, profile images / avatars / company logos (if uploaded).

The legal basis for processing is our contract with the respective customer company (Art. 6(1)(b) GDPR). A Data Processing Agreement (DPA) pursuant to Art. 28 GDPR is concluded between nuuminds and the customer company.

Authentication (Firebase Authentication & Magic Link)

We use Firebase Authentication for secure login via magic link to your email address. Technical data such as IP address and browser information may be processed. Legal bases: Art. 6 (1) lit. b and f GDPR.

Further information: Firebase Privacy Policy

Data Storage (Firebase Firestore)

User data, learning progress, Certificates of Participation and other user-specific data are stored exclusively in Google Cloud Firestore (Firebase) on EU servers (region europe-west3). Legal basis: Art. 6 (1) lit. b GDPR.

Further information: Firebase Privacy Policy

File Storage (Firebase Cloud Storage)

Files generated during use (e.g. Certificates of Participation, profile images or company logos) are stored in Firebase Cloud Storage in Europe. Legal basis: Art. 6 (1) lit. b GDPR.

Further information: Firebase Privacy Policy

Server-side Functions (Firebase Cloud Functions)

We use Firebase Cloud Functions for automations (e.g. generating Certificates of Participation or user management). Processing takes place in Europe (region europe-west3). Legal bases: Art. 6 (1) lit. b and f GDPR.

Further information: Firebase Privacy Policy

4. Analysis Tools (Matomo)

We use a self-hosted instance of Matomo (hosted at All-Inkl) to obtain aggregated usage statistics (e.g. page views, navigation paths). Matomo is configured to anonymize IP addresses before storage and to operate without tracking cookies. Full IP addresses or persistent user identifiers are not stored. Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in a data-minimizing, anonymized reach measurement).

Hosting: We host Matomo exclusively on our own servers, so that all analysis data remains with us and is not passed on.

5. Plugins and Tools

Resend (Contact Form & Transactional Emails)

We use Resend (Resend, Inc., USA) solely for sending essential transactional system emails (e.g. confirmations, technical notices) and for processing messages submitted via the contact form. We do not send newsletters. Data may be transferred to third countries (in particular the USA) based on the EU Standard Contractual Clauses pursuant to Art. 46 GDPR.

Legal bases: Art. 6 (1) lit. b GDPR (performance of a contract / pre-contractual measures where user-initiated actions require an email) and Art. 6 (1) lit. f GDPR (legitimate interest in efficient and secure communication and handling contact form inquiries). Resend has implemented appropriate safeguards via Standard Contractual Clauses to ensure an adequate level of protection when processing data outside the EU.

You can find the Standard Contractual Clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj. Resend's Data Processing Addendum is available at https://resend.com/legal/dpa.

For further information on how Resend processes personal data, please refer to the Resend Privacy Policy at https://resend.com/legal/privacy.

OpenAI (ChatGPT)

We use OpenAI (ChatGPT) to automatically analyze, summarize, or categorize textual input provided in Smart Audits and feedback surveys. Only the text you (or your organization) submit for that specific purpose is processed. We do not intentionally send special category data (Art. 9 GDPR) or directly identifying information, and users are asked not to include such data in free-text fields.

Legal bases: Art. 6 (1) lit. f GDPR (legitimate interest in efficient, consistent, and scalable evaluation for product/service quality improvement) and, where evaluation is part of contractual functionality, additionally Art. 6 (1) lit. b GDPR. No profiling for marketing purposes takes place.

Data may be processed in third countries (including the USA). According to OpenAI, appropriate safeguards (including Standard Contractual Clauses) are implemented. We apply data minimization and avoid transmitting directly identifying personal data.

Further information: https://www.openai.com/privacy-policy/

Google Workspace

We use Google Workspace, a suite of cloud-based productivity and collaboration tools provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (with processing that may involve affiliated companies, including Google LLC, USA), to run efficient internal communication, documentation, and organization processes. Services include, among others, Gmail, Google Drive, Google Calendar, Google Meet, and Google Docs/Sheets/Slides.

Depending on the context, the following personal data may be processed: contact data (e.g., name, business email address), communication contents (e.g., emails, documents, meeting content), and usage/meta data (e.g., IP address, timestamps, logins). We apply data minimization and limit contents to what is necessary.

Legal bases: Art. 6 (1) lit. b GDPR (where use is necessary to perform pre-/contractual obligations, e.g., communication as part of client projects) and Art. 6 (1) lit. f GDPR (legitimate interest in efficient and secure internal collaboration).

We have entered into a data processing agreement pursuant to Art. 28 GDPR with Google (Data Processing Addendum). Data may be transferred to third countries (in particular the USA); Google relies, among other safeguards, on Standard Contractual Clauses. Where available, we use EU locations and avoid transmitting sensitive data beyond what is necessary.

Further information: Google Privacy Policy

Google Drive

We use Google Drive (part of Google Workspace) as a cloud storage solution for secure storage, management, and collaborative editing of files and documents (e.g., project materials, minutes, templates). Access permissions are granted on a need-to-know basis.

In this context, files may contain personal data, such as names and contact details, project-/contract-related information, and—where required for billing/contract performance—billing-relevant information. Processing is purpose-bound and data-minimizing.

Legal bases align with the above Google Workspace section (Art. 6 (1) lit. b and lit. f GDPR). A data processing agreement pursuant to Art. 28 GDPR is in place (DPA); any necessary third-country transfers rely on Standard Contractual Clauses. Where available, we prefer EU storage locations.