Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on data protection, please refer to our Privacy Policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact information in the “Information on the Data Controller” section of this Privacy Policy.

How do we collect your data?

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

Other data is collected by our IT systems automatically or with your consent when you visit the website. This primarily consists of technical data (e.g., internet browser, operating system, or the time the page was accessed). This data is collected automatically as soon as you access this website.

What do we use your data for?

Some of the data is collected to ensure the website functions properly. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated through the website, the data provided will also be processed for contract offers, orders, or other order inquiries.

What rights do you have regarding your data?

You have the right at any time to receive, free of charge, information about the source, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you may revoke that consent at any time with future effect. In addition, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to file a complaint with the competent supervisory authority.

Please feel free to contact us at any time regarding this matter or any other questions you may have about data protection.

2. Hosting

We host our website's content with the following provider:

DomainFactory

The provider is DomainFactory GmbH, c/o WeWork, Neuturmstraße 5, 80331 Munich (hereinafter “DomainFactory”). When you visit our website, DomainFactory collects various log files, including your IP addresses.

For more details, please refer to DomainFactory's Privacy Policy: https://www.df.eu/de/datenschutz/.

The use of DomainFactory is based on Article 6(1)(f) of the GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. If consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s device (e.g., for device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Order Processing

We have entered into a Data Processing Agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law that ensures the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Disclosures

Privacy Policy

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with applicable data protection laws and this Privacy Policy.

When you use this website, various types of personal data are collected. Personal data is information that can be used to identify you personally. This Privacy Policy explains what data we collect and how we use it. It also explains how and for what purpose this is done.

Please note that data transmission over the Internet (e.g., when communicating via email) may be subject to security vulnerabilities. It is not possible to completely protect data from access by third parties.

Note on the Data Controller

The entity responsible for data processing on this website is:

Sirius Minds GmbH
Affiliated institute of the University of Oldenburg
Haarenufer 14
26122 Oldenburg

Other locations:

Ammerländer Heerstraße 138, 26129 Oldenburg
Französische Straße 12, 10117 Berlin

Phone: +49 (0) 441 – 559 701 102
Email: info@sirius-minds.com

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

Retention period

Unless a more specific retention period is stated in this Privacy Policy, we will retain your personal data until the purpose for which it was collected no longer applies. If you submit a valid request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted once these grounds no longer apply.

General Information on the Legal Basis for Data Processing on This Website

If you have consented to the processing of your data, we process your personal data on the basis of Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, provided that special categories of data as defined in Article 9(1) of the GDPR are being processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Article 49(1)(a) of the GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g., via device fingerprinting), data processing is additionally based on Section 25(1) of the German Telemedia Act (TDDDG). You may revoke your consent at any time. If your data is necessary for the performance of a contract or for the implementation of precontractual measures, we process your data on the basis of Article 6(1)(b) of the GDPR. Furthermore, we process your data if it is necessary to comply with a legal obligation on the basis of Article 6(1)(c) of the GDPR. Data processing may also be based on our legitimate interest pursuant to Article 6(1)(f) of the GDPR. The applicable legal bases in each individual case are described in the following sections of this Privacy Policy.

Recipients of personal data

As part of our business operations, we collaborate with various external parties. In some cases, this requires the transfer of personal data to these external parties. We disclose personal data to external parties only if it is necessary for the performance of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Article 6(1)(f) of the GDPR, or if another legal basis permits the disclosure of data. When using data processors, we disclose our customers’ personal data only on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You may withdraw any consent you have already given at any time. The lawfulness of the data processing carried out prior to the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in specific cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6, PAR. 1, SUBPAR. E OR F OF THE GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. YOU CAN FIND THE SPECIFIC LEGAL BASIS ON WHICH PROCESSING IS BASED IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, exercise, or defense of legal claims (objection pursuant to Art. 21(1) of the GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING PURPOSES; THIS ALSO APPLIES TO PROFILING, TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) OF THE GDPR).

Right to File a Complaint with the Competent Regulatory 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, their place of work, or the location of the alleged violation. This right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically—based on your consent or in fulfillment of a contract—provided to you or to a third party in a commonly used, machine-readable format. If you request that the data be transferred directly to another data controller, this will be done only to the extent that it is technically feasible.

Access, Correction, and Deletion

In accordance with applicable legal provisions, you have the right at any time to receive, free of charge, information about your stored personal data, its origin and recipients, and the purpose of the data processing, as well as the right to have this data corrected or deleted, if applicable. You may contact us at any time regarding this matter or with any other questions about personal data.

Right to Restriction of Processing

You have the right to request that the processing of your personal data be restricted. You may contact us at any time to do so. The right to restriction of processing applies in the following cases:

If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification process, you have the right to request that the processing of your personal data be restricted.
If the processing of your personal data was or is unlawful, you may request that the processing be restricted instead of having the data erased.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of being erased.
If you have filed an objection under Article 21(1) of the GDPR, a balancing of your interests against ours must be conducted. Until it is determined whose interests prevail, you have the right to request that the processing of your personal data be restricted.

If you have restricted the processing of your personal data, such data—with the exception of its storage—may be processed only with your consent, or for the purpose of asserting, exercising, or defending legal claims, or to protect the rights of another natural or legal person, or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential information—such as orders or inquiries you send to us as the website operator—this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the padlock icon in your browser’s address bar.

If SSL or TLS encryption is enabled, the data you send to us cannot be read by third parties.

4. Data Collection on This Website

Cookies

Our website uses so-called “cookies.” Cookies are small data packets that do not cause any harm to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your device until you delete them yourself or your web browser deletes them automatically.

Cookies may be set by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain third-party services into websites (e.g., cookies used to process payment services).

Cookies serve various purposes. Many cookies are technically necessary, as certain website features would not work without them (e.g., the shopping cart feature or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.

Cookies that are necessary for carrying out the electronic communication process, for providing certain functions you have requested (e.g., the shopping cart feature), or for optimizing the website (e.g., cookies for measuring website traffic) are stored pursuant to Article 6(1)(f) of the GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies to ensure the technically flawless and optimized provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG); consent may be revoked at any time.

You can configure your browser to notify you when cookies are set, to allow cookies only on a case-by-case basis, to block cookies in specific cases or generally, and to enable the automatic deletion of cookies when you close your browser. Disabling cookies may limit the functionality of this website.

You can find out which cookies and services are used on this website in this Privacy Policy.

CCM19

Our website uses CCM19 to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies, and to document this in compliance with data protection regulations. This technology is provided by Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn (hereinafter “CCM19”).

When you visit our website, a connection is established with CCM19’s servers to obtain your consents and other statements regarding cookie usage. CCM19 then stores a cookie in your browser to associate the consents you have granted—or their revocation—with your account. The data collected in this manner is stored until you request that we delete it, delete the CCM19 cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention requirements remain unaffected.

CCM19 is used to obtain the legally required consent for the use of cookies. The legal basis for this is Article 6(1), first sentence, subparagraph (c) of the GDPR.

Order Processing

Contact Form

If you submit inquiries to us via the contact form, we will store the information you provide in the inquiry form—including the contact information you provide there—for the purpose of processing your inquiry and in case we have any follow-up questions. We will not share this information without your consent.

This data is processed on the basis of Article 6(1)(b) of the GDPR, provided that your inquiry is related to the performance of a contract or is necessary for the implementation of precontractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of inquiries directed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR), provided that consent was requested; consent may be withdrawn at any time.

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

Inquiries by email, phone, or fax

If you contact us by email, phone, or fax, we will store and process your inquiry—including all personal data contained therein (name, inquiry)—for the purpose of handling your request. We will not disclose this data without your consent.

The data you send us via contact requests will remain with us until you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular statutory retention periods—remain unaffected.

Registration on this website

You can register on this website to access additional features. We use the information you provide solely for the purpose of providing the specific offer or service for which you have registered. You must provide all required information requested during registration. Otherwise, we will reject your registration.

For important changes—such as changes to the scope of our services or technically necessary changes—we will use the email address you provided during registration to notify you.

The data entered during registration is processed for the purpose of fulfilling the user relationship established by the registration and, where applicable, to initiate further contracts (Art. 6(1)(b) GDPR).

We will store the data collected during registration for as long as you remain registered on this website; it will then be deleted. Statutory retention periods remain unaffected.

5. Social Media

This website uses features from the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Every time you access a page on this website that contains LinkedIn elements, a connection is established with LinkedIn’s servers. LinkedIn is notified that you have visited this website using your IP address. If you click the LinkedIn “Recommend” button while logged into your LinkedIn account, LinkedIn can associate your visit to this website with you and your user account. Please note that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it is used by LinkedIn.

Use of this service is based on your consent pursuant to Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG. You may withdraw your consent at any time.

Data transfers to the United States are based on the European Commission's Standard Contractual Clauses. For details, see here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de

For more information on this, please see LinkedIn's Privacy Policy at: https://www.linkedin.com/legal/privacy-policy.

The company is certified under the “EU-U.S. Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information on this, please visit the provider’s website at the following link: https://www.dataprivacyframework.gov/participant/5448.

6. Newsletter

Newsletter Information

If you would like to subscribe to the newsletter offered on this website, we need your email address as well as information that allows us to verify that you are the owner of the email address provided and that you consent to receiving the newsletter. No other data is collected, or is collected only on a voluntary basis. We use this data exclusively to send you the requested information and do not share it with third parties.

The processing of the data entered in the newsletter sign-up form is based solely on your consent (Art. 6(1)(a) GDPR). You may revoke your consent to the storage of your data and email address, as well as their use for sending the newsletter, at any time—for example, by clicking the “Unsubscribe” link in the newsletter. The lawfulness of any data processing that has already taken place remains unaffected by this revocation.

The data you have provided to us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter, and will be deleted from the newsletter distribution list after you unsubscribe or once the purpose for which it was collected no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our sole discretion within the scope of our legitimate interest pursuant to Article 6(1)(f) of the GDPR.

Data that we have stored for other purposes is not affected by this.

After you unsubscribe from the newsletter mailing list, your email address may be stored on a blacklist by us or the newsletter service provider, if necessary, to prevent future mailings. The data from the blacklist is used solely for this purpose and is not combined with any other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) of the GDPR). There is no time limit on storage in the blacklist. You may object to this storage if your interests outweigh our legitimate interest.

7. Plugins and Tools

YouTube

This website embeds videos from YouTube. The website is operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of our web pages that includes YouTube, a connection is established with YouTube's servers. In the process, the YouTube server is informed which of our pages you have visited.

In addition, YouTube may store various cookies on your device or use similar technologies for recognition purposes (e.g., device fingerprinting). This allows YouTube to obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve the user experience, and prevent fraud. Additionally, the collected data is processed within the Google advertising network.

If you are logged in to your YouTube account, you are allowing YouTube to associate your browsing activity directly with your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube to ensure that our online offerings are presented in an appealing manner. This constitutes a legitimate interest within the meaning of Article 6(1)(f) of the GDPR. If consent has been obtained, processing is carried out exclusively on the basis of Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG, provided that the consent covers the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent may be revoked at any time.

For more information on how user data is handled, please see YouTube's Privacy Policy at: https://policies.google.com/privacy?hl=de.

8. E-commerce and Payment Providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data to establish, define the terms of, and modify our contractual relationships. We collect, process, and use personal data regarding the use of this website (usage data) only to the extent necessary to enable the user to access the service or to bill the user. The legal basis for this is Article 6(1)(b) of the GDPR.

The customer data collected will be deleted after the order is completed or the business relationship is terminated, and after any applicable statutory retention periods have expired. Statutory retention periods remain unaffected.

9. Audio and Video Conferences

Data Processing

We use online conferencing tools, among other methods, to communicate with our customers. The specific tools we use are listed below. When you communicate with us via video or audio conference over the Internet, your personal data is collected and processed by us and by the provider of the respective conferencing tool.

The conferencing tools collect all data that you provide or use in connection with the tools (email address and/or your phone number). In addition, the conferencing tools process the duration of the conference, the start and end times of your participation in the conference, the number of participants, and other “contextual information” related to the communication process (metadata).

In addition, the tool provider processes all technical data necessary for handling online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.

If content is exchanged, uploaded, or otherwise made available within the tool, it is also stored on the tool provider’s servers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have full control over the data processing activities of the tools we use. Our options depend largely on the corporate policies of the respective providers. For more information on data processing by the conference tools, please refer to the privacy policies of the respective tools, which we have listed below this text.

Purpose and Legal Basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer specific services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of these tools serves to generally simplify and expedite communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) of the GDPR). To the extent that consent has been requested, the use of the relevant tools is based on this consent; consent may be revoked at any time with future effect.

Retention period

The data we collect directly through our video and conferencing tools is deleted from our systems as soon as you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no control over how long your data is stored by the operators of the conferencing tools for their own purposes. For more details, please contact the operators of the conferencing tools directly.

Conference Tools Used

We use the following conferencing tools:

Zoom

We use Zoom. This service is provided by Zoom Communications Inc., San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s Privacy Policy: https://www.zoom.com/de/trust/privacy/privacy-statement/.

Data transfers to the United States are based on the European Commission's Standard Contractual Clauses. For details, see here: https://www.zoom.com/de/trust/privacy/privacy-statement/.

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams Privacy Statement: https://privacy.microsoft.com/de-de/privacystatement.

Talent LMS

We use Talent LMS to deliver our learning content. For more information on data processing by Talent LMS, click here: GDPR-Compliant LMS – eLearning Software | TalentLMS

LMS Tutor

We use Tutor LMS to deliver our learning content. For more information about data processing by Tutor LMS, please see here: Tutor LMS Privacy Policy | Your Data Protection Matters | Tutor LMS

edoobox

We use edoobox to deliver our learning content. For more information about edoobox's data processing practices, please see the Edoobox Privacy Policy here: Edoobox Privacy Policy

LimeSurvey

We use Limesurvey to conduct surveys of our (potential) participants. For more information on data processing by Limesurvey, please see here: Privacy Notice