With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). The terms used are not gender specific.
GongGamm gGmbH
Seydlitzstraße 24
12249, Berlin Germany
Dr. Lee, Yoo Min, Ph.D.
Managing Director & Head Researcher
E-Mail: contact@gonggamm.org
Tel.: +49 30 2862 2735
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Categories of data subjects
Purposes of processing
Below you will find an overview of the legal bases of the GDPR (General Data Protection Regulation), on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk. The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if there are certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Cookies are text files containing data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the place where a video was watched. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as "user IDs").
The following cookie types and functions are distinguished:
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.
Storage period: If we do not provide you with any explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies ( collectively referred to as "opt-out"). You can initially declare your objection using the settings in your browser, e.g. by deactivating the use of cookies (which can also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ will. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the user consents to the use of cookies or the processing mentioned in the context of the cookie consent management procedure and providers can be obtained and managed and revoked by the users. The declaration of consent is stored here so that the query does not have to be repeated and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of the consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.
We process the data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships and related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g respond
We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and the corporate organization. We only pass on the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to telecommunications, transport and other auxiliary services involved as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or during the data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after statutory warranty and comparable obligations have expired, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it has to be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If it is necessary to register a customer account, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent registrations and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the customer's responsibility to back up their data upon termination of the customer account.
Economic analyzes and market research: For business reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned includes contractual partners, interested parties, customers, Visitors and users of our online offer can fall.
The analyzes are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users together with their information, e.g. on services used. The analyzes serve us alone and are not disclosed externally, unless they are anonymous analyzes with summarized, i.e. anonymous values. Furthermore, we take the privacy of the users into account and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
Education and training services: We process the data of the participants in our education and training offers (uniformly referred to as "apprentices and trainees") in order to be able to provide them with our training services. The data processed here, the type, scope, purpose and the necessity of their processing are determined by the underlying contractual and training relationship.The forms of processing also include the performance assessment and the evaluation of our services and those of the teachers.
As part of our activities, we can also process special categories of data, in particular information on the health of trainees and trainees as well as data revealing ethnic origin, political opinions, religious or ideological beliefs. If necessary, we obtain the express consent of the trainees and trainees and otherwise only process the special categories of data if it is necessary to provide the training services, for the purposes of health care, social protection or the protection of vital interests of the trainees and trainees is required.
Insofar as it is necessary for the fulfillment of our contract, to protect vital interests or by law, or if the trainees and trainees have given their consent, we disclose or transmit the data of the trainees and trainees to third parties or agents, such as authorities, in compliance with the professional regulations or in the field of IT, office or comparable services.
Publication activity: We process the data of our contact partners, interview partners and other persons who are the subject of our publishing, editorial, journalistic and related activities. In this context, we refer to the application of protective regulations for freedom of expression and freedom of the press in accordance with Article 85 GDPR in conjunction with the respective national laws. The processing serves to fulfill our order activities and otherwise takes place in particular on the basis of the general interest in information and media offers.
As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively "payment service providers").
The data processed by the payment service provider includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service provider may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this we refer to the terms and conditions and the data protection information of the payment service provider.
The terms and conditions and data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to this for the purpose of further information and the assertion of revocation, information and other data subject rights.
Services and service providers used:
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the course of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.
On the one hand, the server log files can be used for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability.
Types of data processed: content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses). Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness.
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Users can create a user account. As part of the registration, the users are informed of the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfillment of obligations. The processed data includes in particular the login information (user name, password and an e-mail address).
When using our registration and login functions and when using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users can be informed by email about processes that are relevant to their user account, such as technical changes.
Registration with pseudonyms: Users may use pseudonyms as user names instead of real names.
Deletion of data after termination: If users have terminated their user account, their data will be deleted with regard to the user account, subject to a legal permission, obligation or consent of the user.
It is the user's responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the contract period.
The community functions we provide allow users to engage in conversations or other exchanges with one another. We ask you to note that the use of the community functions is only permitted in compliance with the applicable legal situation, our conditions and guidelines as well as the rights of other users and third parties.
Protection of your own data: Users decide for themselves which data they disclose about themselves within our online offer. For example, when users provide information about themselves or participate in conversations. We ask users to protect their data and only publish personal data with caution and to the extent necessary. In particular, we ask users to note that they must protect the access data in a very special way and use secure passwords (i.e., above all, long and random character combinations).
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipient or legal permission. If the content of the newsletter is specifically described when registering for it, it is decisive for the consent of the user. Our newsletter also contains information about our services and us.
In order to register for our newsletters, it is generally sufficient if you enter your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else's email address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the email address in a blacklist (so-called "blocklist") solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Notes on the legal basis: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising for existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
Prerequisite for the use of free services: Consent to the sending of mailings can be made dependent on the use of free services (e.g. access to certain content or participation in certain campaigns). If users would like to take advantage of the free service without registering for the newsletter, we ask that you contact us.
The polls and surveys we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing the IP address to display the survey in the user's browser or using a temporary cookie (session cookie) to resume the survey enable) or users have consented.
Notes on the legal bases: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants' data is based on our legitimate interests in conducting an objective survey.
The web analysis (also referred to as "reach measurement") serves to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, recognize at what time our online offer or its functions or content are used most frequently or invite you to reuse them. We can also understand which areas need optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offer or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar processes can be used for the same purpose. This information can include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this can also be processed depending on the provider.
The IP addresses of the users are also saved. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also saved. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we and the providers of the online marketing process do not know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar processes. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network connects the user's profile with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, we can use so-called conversion measurements to check which of our online marketing processes have led to a so-called conversion, i.e. e.g. to the conclusion of a contract with us. The conversion measurement is only used to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data can be processed outside of the European Union. This can result in risks for users, for example because it could make it more difficult to enforce user rights.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created based on usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the possibility of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Facebook: We are in partnership with Facebook Ireland Ltd. responsible for the collection (but not further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see “Things Done and Provided by You and Others” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook data policy statement: https://www.facebook.com/policyhttps://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services called "Page Insights" to site operators, so that they can gain insights into how people are using their Pages and interact with the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook itself has declared its willingness to fulfill the rights of the data subject (ie users can, for example, send information or requests for deletion directly to Facebook). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on page insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).
Services and service providers used:
The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).
If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Our data protection information can also contain further information on the storage and deletion of data, which apply primarily to the respective processing.
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your participation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.
As a data subject, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:
This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.