Social Media Privacy Policy

This Privacy Policy informs you of the extent to which we process your personal data (hereinafter referred to as “data”) in connection with our social media accounts.

1. Data controller

The data controller as defined in the provisions of the General Data Protection Regulation (GDPR) is:

Berlitz Deutschland GmbH
Hahnstrasse 68–70
60528 Frankfurt, Germany

Tel.: +49 (0)69 666 08 90
Web: www.berlitz.com/en-de
Email: info@berlitz.de

2. Contact details for our data protection officer

Email: datenschutz@berlitz.de

3. Facebook

a) Joint controllers for data processing purposes

We operate our Facebook Fan Page on the online social network platform provided by Facebook Ireland Limited (“Facebook Ireland”). Together with Facebook Ireland, we are jointly responsible for data processing in connection with this fan page in accordance with the provisions of the General Data Protection Regulation (“GDPR”). Without limitation, this includes data processing related to Page Insights, see bb) Use of Insights and cookies. When you visit this Fan Page, personal data is processed by Facebook Ireland and us as joint controllers.

Facebook Ireland bears primary responsibility for processing Insights data under the GDPR. Facebook Ireland therefore assumes all obligations under the GDPR with regard to the processing of Insights data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR). Facebook Ireland remains solely responsible for the processing of personal data in connection with Page Insights that does not fall within the scope of the Page Insights addendum.

Based on agreements in place with Facebook Ireland that also relate to joint responsibility for data processing, from a practical standpoint it is best to address any requests for access and to assert any other rights to which you are entitled as a data subject, directly to Facebook Ireland. As the operator of the social network and in light of the ability to integrate Facebook Fan Pages into the social network, Facebook Ireland is in a position to access any required information using its direct access options and to take any necessary measures and provide information itself. You may also send inquiries to us and, of course, we are ready to assist you at any time, and to comply with our obligations as controller.

The underlying Facebook Ireland Terms of Service (including the other terms and policies set forth therein), are available at:

https://www.facebook.com/legal/terms

supplemented by the Page Insights addendum concerning joint controllers, available at

https://www.facebook.com/legal/terms/page_controller_addendum

b) What data do we process and for what purpose?

aa) Operation of our Fan Page

The purpose of operating our Facebook Fan Page is to communicate with users and visitors to Facebook Ireland’s social network and promote interaction and communication. On occasion, we provide information about our company and our offerings. This may include past or current events, special promotions and offers, etc.

We can also obtain statistics on visits and visitors with the aid of our Facebook Fan Page. This information is compiled by Facebook Ireland. This enables us to better and more effectively manage the marketing of our activities. In doing so, we may also receive information about Facebook profiles of individual users who like our Fan Page and/or use applications on the page. This allows us to provide improved content and features to these users through our Facebook Fan Page.

To further improve our content, we may also use information we collect during your visit to perform demographic and geographic assessments based on that information. This enables us to place targeted, interest-based advertisements without directly knowing your identity as a visitor.

If you use more than one device when visiting Facebook Ireland, data may be collected and analyzed across devices if you visit our Fan Page as a registered Facebook user while logged-in to your Facebook profile.

Visitor statistics compiled in this manner are sent to us solely in anonymized form. Access to the underlying data is not possible.

bb) Use of Insights and cookies

As part of our Fan Page, we use “Insights” provided by Facebook Ireland to obtain anonymous statistical data about visitors to our Fan Page.

When you visit our Fan Page, Facebook Ireland places a data package, a cookie, on your device for this purpose that contains an identifiable user code. The user code can be associated with your data if you are registered as a user on Facebook. The information stored in this context is processed by Facebook. It is also possible that third parties may use information from Facebook cookies to provide services to companies that advertise on Facebook.

The cookie is active for two years unless deleted at an earlier time.

For more information on Page Insights, see 3a)

For more information on how Facebook Ireland uses cookies, see the Facebook cookie policy:

https://www.facebook.com/policies/cookies/

c) Legal basis

We process personal data on the basis of our legitimate interests in effective interaction with visitors to our social media accounts, visitors to our profile and in the context of communicating with users visiting our social media accounts, including our company profile, pursuant to Art. 6(1)(f) GDPR.

d) Sharing data and data transmission to the United States

When you visit our Fan Page, any data collected may be transferred to Facebook Inc. in the United States and processed there. The European Commission has not issued an adequacy decision for transfers of data to the United States. Facebook ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clause will be provided upon request. Please contact If you have any questions regarding your personal data, the provision of information, rectification, blocking, objection or the erasure of data or want your data to be transferred to another company, please contact if you are interested in receiving these contractual clauses.

We do not share any data with third parties within the scope of operating our Fan Page.

e) Options for objecting via your Facebook account

As a Facebook user, you have the option of using the advertising preference settings in your Facebook account to set the extent to which your user behavior can be recorded when you visit our Fan Page. Facebook also provides an opt-out form:

https://www.facebook.com/help/contact/1994830130782319

4. Instagram

a) Joint controllers for data processing purposes

We operate our own Instagram account. Instagram is a Facebook product operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (hereinafter: “Facebook”). Together with Facebook Ireland, we are jointly responsible for data processing in connection with this fan page in accordance with the provisions of Art. 4(7) GDPR. Without limitation, this includes data processing related to Page Insights, see section 3 b) bb) Use of Insights and cookies. When you visit our Instagram corporate page, personal data is processed by Facebook Ireland and us as joint controllers.

For information on responsibility for Insights data and requests for information under the GDPR, see section 3a).

Use of this service is governed solely by Instagram’s Terms of Use (including any other terms and policies set forth therein). They may be accessed at https://help.instagram.com/581066165581870.

For information on data processing by Facebook, please see the Instagram data policy at: https://help.instagram.com/519522125107875.

b) What data do we process and for what purpose?

aa) Operation of our Instagram account

The purpose of operating our Instagram account is to make contact with the users and visitors to the Instagram social network and foster interaction and communication. On occasion, we provide information directly about our company and our offerings. This may include past or current events, special promotions and offers, etc.

In this context, we may receive statistics about visits and interactions with our account. This information is compiled by Facebook Ireland. This enables us to better and more effectively manage the marketing of our activities. In doing so, we may sometimes receive information about Instagram profiles of individual users who like our Fan Page and/or use applications on the page. This allows us to provide improved content and features to these users through our Instagram Fan Page.

To further improve our content, we may also use information we collect during your visit to our account to perform demographic and geographic assessments based on that information. This enables us to place targeted, interest-based advertisements without directly knowing your identity as a visitor.

If you use more than one device when visiting Instagram, data may be collected and analyzed across devices if you visit our Fan Page as a registered Instagram user while logged-in to your Instagram profile.

Visitor statistics compiled in this manner are sent to us solely in anonymized form. Access to the underlying data is not possible.

bb) Use of Insights and cookies

As part of our Fan Page, we use “Insights” provided by Facebook Ireland to obtain anonymous statistical data about visitors to our Fan Page.

When you visit our Fan Page, Facebook Ireland places a data package, a cookie, on your device for this purpose that contains an identifiable user code. The user code can be associated with your data if you are registered as a user on Instagram. The information stored in this context is processed by Facebook. It is also possible that third parties may use information from Facebook cookies to provide services to companies that advertise on Facebook.

The cookie is active for two years unless deleted at an earlier time.

For more information on Page Insights and the use of cookies, see sections 3a) and 3b) bb.

c) Legal basis

We process personal data on the basis of our legitimate interests in effective interaction with visitors to our Instagram account, visitors to our profile and in the context of communicating with users visiting our social media accounts, including our company profile, pursuant to Art. 6(1)(f) GDPR.

d) Sharing data and data transmission to the United States

We do not share any data with third parties within the scope of operating our corporate website.

e) Options for objecting via your Instagram account

As an Instagram user, you have the option of using the advertising preference settings in your account to set the extent to which your user behavior can be recorded when you visit our Fan Page. Facebook also provides an opt-out form:

https://www.facebook.com/help/contact/1994830130782319

5. YouTube

a) What data do we process and for what purpose?

YouTube is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. No personal data is processed directly by us in relation to our YouTube channel.

However, if you enter data on YouTube itself as a registered user, such as your user name and content published under your own account, this data is processed by us when we share your comments, reply to your comments, or write a post that links to your profile. In such cases, data you enter on YouTube, in particular your (user) name and content published in your account, will be processed to the extent that it is included on our Fan Page and made available to our fans.

Google Ireland Limited is the controller within the meaning of Art. 4(7) GDPR for all further data processing in the context of the use of the YouTube service and its functionalities. We have no influence on the type and scope of the data processed by Google as part of the YouTube service, the type of processing, the use of the data or the transfer of this data to third parties.

b) Legal basis

We process personal data on the basis of our legitimate interests in effective interaction with visitors to our YouTube account, visitors to our profile and in the context of communicating with users visiting our social media accounts, including our company profile, pursuant to Art. 6(1)(f) GDPR.

c) Sharing data and data transmission to the United States

It is possible that data collected when visiting our YouTube channel will be forwarded to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, located in the United States, and processed there. The European Commission has not issued an adequacy decision for transfers of data to the United States. Google ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clause will be provided upon request. Please contact If you have any questions regarding your personal data, the provision of information, rectification, blocking, objection or the erasure of data or want your data to be transferred to another company, please contact if you are interested in receiving these contractual clauses.

In addition, you can access the updated terms of use and contractual protections here https://business.safety.google/gdpr/

In addition, please refer to statements concerning Google’s use of data within the Google Partner Network at: http://www.google.com/intl/de/policies/privacy/partners/

Otherwise, we do not pass on data to third parties within the framework of operating our corporate profile.

6. LinkedIn

a) Joint controllers for data processing purposes

LinkedIn is a product provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Together with LinkedIn, we are jointly responsible for data processing in connection with our company profile, in particular with regard to the “Page Insights” function, in accordance with the provisions of Art. 4(7) GDPR. When you visit our company profile, personal data is processed by LinkedIn and us as joint controllers.

LinkedIn bears primary responsibility for processing Page Insights data under the GDPR; see also section b) cc) User analysis. LinkedIn therefore assumes all obligations under the GDPR with regard to the processing of Page Insights data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR). LinkedIn remains solely responsible for the processing of personal data in connection with Page Insights that does not fall within the scope of the Page Insights joint controller addendum.

The Page Insights Joint Controller Addendum may be accessed at: https://legal.linkedin.com/pages-joint-controller-addendum.

The LinkedIn privacy policy is available at: https://www.linkedin.com/legal/privacy-policy

b) What data do we process and for what purpose?

aa) Interaction and communication

The purpose of operating our company profile on LinkedIn is to interact with and communicate with users and visitors on the LinkedIn social network. We provide information that directly concerns our company and its associated offerings.

As a user of a LinkedIn profile, we may process data provided by you as a LinkedIn member. This includes any information you have stored in your profile, messages you send us, and interaction with our content. In particular, this will be the case if you share or recommend our content, comment on it, contact us, or when you post a link to our website within LinkedIn.

We process personal data on the basis of our legitimate interests in effective interaction with visitors to our LinkedIn account, visitors to our profile and in the context of communicating with users visiting our social media accounts, including our company profile, pursuant to Art. 6(1)(f) GDPR.

bb) Employment applications

If you submit your application to us via LinkedIn or if you indicate interest in a job offer that we make to you, the data you provide (e.g. name, email address, desired location, data of your LinkedIn profile, etc.), your communication and application-related documents you submit will be processed exclusively for the purpose of processing and handling your application request. This is done via the softgarden platform.

We process personal data from applicants on the basis of section 26(1) BDSG. According to this, it is permitted to process data that is required in connection with a decision on, or the conclusion of, an employment relationship.

If the data is still required after the completion of the application procedure, for instance for prosecution purposes, we are permitted to process the data for the protection of our legitimate interests pursuant to Art. 6(1)(f) GDPR, i.e. for the assertion and/or defense of claims.

cc) User analysis

LinkedIn provides us with a variety of information about visits and visitors to our company profile by means of the “Page Insights” service. This information is provided by LinkedIn and enables us to better and more effectively manage the marketing of our activities. This is so-called “aggregated data” with which it is not possible to identify you personally. Any data processing performed within the context of the “Page Insights” service is done at the sole responsibility of LinkedIn. In this context, we have no access to personal data except in aggregated form.

c) Sharing data and data transmission to the United States

Data collected during visits to our company profile may be transferred to LinkedIn Corporation, based in the United States, and processed there. The European Commission has not issued an adequacy decision for transfers of data to the United States. LinkedIn ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clause will be provided upon request. Please contact If you have any questions regarding your personal data, the provision of information, rectification, blocking, objection or the erasure of data or want your data to be transferred to another company, please contact if you are interested in receiving these contractual clauses.

Otherwise, we do not pass on data to third parties within the framework of operating our corporate profile.

7. XING

a) What data do we process and for what purpose?

aa) Interaction and communication

We operate a corporate profile on the online platform operated by the “XING” social network, New Work SE Dammtorstrasse 30, 20354 Hamburg, Germany (“Xing” ), where your personal data is processed. The purpose of operating our company profile on XING is to get in touch with users and visitors to this social network, to engage in communication, and to be able to receive applications from users directly via XING. We provide information that directly concerns our company and its associated offerings.

As a user of a XING profile, we may process data provided by you as a XING member. This includes any information you have stored in your profile, messages you send us, and interaction with our content. In particular, this will be the case if you share or recommend our content, comment on it or when you post a link to our website within XING.

For information on what data is processed by XING and for what purposes it is used, please see the XING privacy policy: https://privacy.xing.com/en

We process personal data on the basis of our legitimate interests in effective interaction with XING users, visitors to our profile, to be able to receive job applications from users directly via XING, and in the context of communicating with users visiting our social media accounts, including our company profile, pursuant to Art. 6(1)(f) GDPR.

bb) Employment applications

If you submit your application to us via XING or if you indicate interest in a job offer that we make to you, the data you provide (e.g. name, email address, desired location, data of your XING profile, etc.), your communication and application-related documents you submit will be processed exclusively for the purpose of processing and handling your application request. This is done via the softgarden platform.

b) Sharing data and data transmission to the United States

We do not pass on data to third parties within the framework of operating our corporate profile.

8. Salesforce Social Studio

a) What data do we process and for what purpose?

We use the Salesforce Social Studio service, a product provided by Salesforce Marketing Cloud, represented in Germany by Salesforce.com Germany GmbH, Erika-Mann-Strasse 31, 80636 Munich, Germany (“Salesforce”), to communicate with you and to analyze the behavior of visitors to our social media accounts. We are informed if there is a reaction to our accounts or posts on social networks. In this context, the respective user name and comment will be displayed to us.

b) Legal basis

Processing in this manner is performed on the basis of our overriding legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR.

9. Fanpage Karma

a) What data do we process and for what purpose?

We use the Fanpage Karma service provided by uphill GmbH, Oranienstrasse 188, 10999 Berlin, Germany, to communicate with you, optimize our social media accounts and evaluate visitor usage.

Fanpage Karma processes personal data such as your profile name via access to the social media platforms that we have authorized in order to compile statistics and to determine our reach and the number of views.

b) Legal basis

Processing in this manner is performed on the basis of our overriding legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR.

Further information on data protection can be found here: https://www.fanpagekarma.com/privacy

10. Data retention period

We will only store personal data for as long as is required for the purpose for which it is processed or until you withdraw your consent to the processing of such data. Where statutory retention obligations must be complied with, the storage period for certain data may be up to 10 years, regardless of the processing purposes.

11. Your rights as a data subject

a) Right of access

On request, we will provide you with information on the personal data stored on you, at any time and free of charge.

b) Rectification, erasure, processing restrictions (blocking), objection

If you no longer consent to the storage of your personal data or if your personal data is no longer accurate, we will initiate the erasure or blocking of your data at your request or ensure that your data is updated accordingly (to the extent possible in accordance with the applicable laws and regulations). The same applies if you want your data only to be processed subject to certain restrictions in the future. You have the right to object in particular in cases in which your data is necessary for the performance of a task carried out in the public interest or on the basis of our legitimate interest, as well as profiling based on this. You also have such a right to object in the case of data processing for the purpose of direct advertising.

c) Right to withdraw consent with future effect

You can withdraw your given consent at any time with future effect. The withdrawal of your consent will, however, in no way affect the lawfulness of the processing of your data before the time of withdrawal.

d) Data portability

You have the right to data portability in cases where data is processed on the basis of a contract, pre-contractual negotiations, consent or by means of an automated process. On request, we will provide you with your data in a structured, commonly used and machine-readable format so that you can transfer the data to another competent party, where required.

e) Restriction of processing

Data which cannot be used to identify the affected party, for example which has been anonymized for analytical purposes, is not affected by the above rights. The provision of information, erasure, blocking, rectification or transfer of data to another company may be possible if you provide us with additional information which enables an identification by us.

f) Asserting your rights as a data subject and your right to lodge a complaint

If you have any questions regarding your personal data, the provision of information, rectification, blocking, objection or the erasure of data or want your data to be transferred to another company, please contact datenschutz@berlitz.de.

You also have the option to complain to a supervisory authority on account of your rights as a data subject.