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Privacy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Persons in charge
Vaia
Briennerstrasse 59
80333 Munich
Germany

info@hellovaia.com
Christian Felgenhauer, Simon Hohentanner, Till Söhlemann, Maurice Khudhir
www.hellovaia.com/terms

support@hellovaia.com
Types of data processed:
– Personal data (e.g., names, addresses).
– Contact data (e.g., e-mail, phone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter, we also refer to the data subjects collectively as “users”).
Purpose of the processing
– Making available the online offer, its functions and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing.
Terminology used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

“Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Relevant legal bases
In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing activities. If the legal basis is not mentioned in the privacy statement, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing to fulfil our services and carry out contractual measures and respond to inquiries is Art. 6(1)(b) DSGVO, the legal basis for processing to fulfil our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
Security measures
We take appropriate technical and organizational measures in accordance with Art. 32 DSGVO, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data compromise. 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 (Article 25 of the GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 (1) lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of using third-party services or disclosing, or transferring data to third parties, this will only happen if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 DSGVO.

You have according to. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

You have the right, in accordance with Art. 17 DSGVO, to request that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 DSGVO, to request restriction of the processing of the data.

You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 DSGVO and to request that it be transferred to other data controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
Right of withdrawal
You have the right to revoke any consent given in accordance with Art. 7 (3) DSGVO with effect for the future.
Right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against processing for direct marketing purposes.
Cookies and right to object in the case of direct advertising
Cookies” are small files that are stored on users’ computers. Various data can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if it is only their cookies, it is called “first-party cookies”).

We may use temporary and permanent cookies and explain this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/oder the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that not all functions of this online offer can then be used.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 und 4, Abs. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 Abs. 1 Nr. 2 und 3, Abs. 4 HGB (commercial letters).

According to legal requirements in Austria, storage is carried out in particular for 7 years in accordance with § 132 para. 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Business-related processing
In addition, we process
– Contract data (e.g., subject matter of the contract, term, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
External payment service providers
We use external payment service providers through whose platforms users and we can make payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html).

In the context of the performance of contracts, we use the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Furthermore, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.

The data processed by the payment service providers 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 in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card-related information, but only information with confirmation or negative information of the payment. Under certain circumstances, payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.

For payment transactions, the terms and conditions and data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lie in the administration, financial accounting, office organization, and archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transmit data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, organizers and other business partners, e.g. for the purpose of later contact. This data, most of which is company-related, is generally stored permanently.
Business analyses and market research
In order to operate our business economically and 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.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details, for example, of the services they have used. The analyses serve us to increase user-friendliness, the optimization of our offer and business management. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they will be deleted or anonymized upon the termination of the user, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general tendency analyses are created anonymously, if possible.
Participation in affiliate partner programs
Within our online offer, we use industry-standard tracking measures on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer) pursuant to Art. 6 (1) lit. f DSGVO, insofar as these are necessary for the operation of the affiliate system. In the following, we explain the technical background to users.

The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or third-party services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take advantage of the offers.

In summary, it is necessary for the online offer that we can track whether users who are interested in affiliate links and/or the offers available on our website subsequently take up the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values, which may be part of the link or otherwise set, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, affiliate ID and categorizations.

The online identifiers of the users used by us are pseudonymous values. That is, the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us to determine whether the same user who clicked on an affiliate link or became interested in an offer via our online offer has taken advantage of the offer, i.e. has concluded a contract with the provider, for example. However, the online identifier is personal to the extent that the partner company and also us, the online identifier together with other user data. Only in this way can the partner company inform us whether the user has taken up the offer and we can pay out the bonus, for example.
Data protection information in the application process
We process applicant data only for the purpose of and within the scope of the application process in accordance with legal requirements. Applicant data is processed to fulfil our (pre)contractual obligations within the scope of the application procedure in accordance with Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO insofar as the data processing becomes necessary for us, e.g. within the scope of legal procedures (in Germany, § 26 BDSG also applies).

The application process requires applicants to provide us with applicant data. The necessary applicant data are marked if we offer an online form, otherwise results from the job descriptions and basically include the personal details, postal and contact addresses and the documents belonging to the application, such as a cover letter, resume and certificates. In addition, applicants may voluntarily provide us with additional information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in the manner and to the extent set out in this privacy policy.

Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are voluntarily communicated within the scope of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a DSGVO (e.g. health data, if this is necessary for the exercise of the profession).

If provided, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they have encrypted themselves. We cannot, therefore, accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend rather using an online form or sending by post. Because instead of applying via the online form and e-mail, applicants still have the option of sending us the application by post.

The data provided by applicants may be processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Subject to a justified withdrawal by the applicants, the deletion will take place after the expiry of a period of six months so that we can answer any follow-up questions about the application and satisfy our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
Registration function
Users can create a user account. As part of the registration process, the required mandatory information is provided to users and processed on the basis of Art. 6 (1) lit. b DSGVO for purposes of providing the user account. The processed data includes in particular the login information (name, password as well as an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users may be informed about information relevant to their user account, such as technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal obligation to retain it. It is the responsibility of users to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.
Contacting
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) (b) DSGVO. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

We delete the inquiries if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.

Registration data: To register for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.

The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. DSGVO in conjunction with. § Section 7 (3) UWG.

The logging of the registration process takes place on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users and furthermore allows us to prove consent.

Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – dispatch service provider
The dispatch of the newsletter is carried out by means of the dispatch service provider [NAME, ADDRESS, COUNTRY]. You can view the privacy policy of the shipping service provider here: [LINK TO PRIVACY POLICY]. The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO and an order processing agreement pursuant to Art. 28 para. 3 p. 1 DSGVO.

The dispatch service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Hosting and e-mail dispatch
The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, metadata and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
We, respectively our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

VWO

Use of VWO – Visual Website Optimizer Within our online offer, based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the service Visual Website Optimizer (an offer of Wingify Software Private Limited, 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India) is used. Visual Website Optimizer allows to track the effect of different changes on a website (e.g. changes in input fields, design, etc.) within the framework of so-called “A/B testing”, “click tracking” and “heat maps”. A/B tests are used to improve the usability and performance of online offerings. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of content or labels of navigation elements may differ. Subsequently, based on the behavior of the users, e.g. longer stay on the website or more frequent interaction with the elements, it can be determined which of these websites or elements are more likely to meet the needs of the users. “Click tracking” allows to overview users’ movements within an entire online offer. Since the results of these tests are more accurate when users’ interactions can be tracked over time (e.g., being able to see if a user likes to return), cookies are usually stored on users’ computers for these testing purposes. “Heatmaps” are mouse movements of users that are combined to form an overall picture, which can be used, for example, to identify which website elements are preferred and which website elements users prefer less. Cookies are stored on users’ devices only for these test purposes. Only pseudonymous user data is processed. For more information, please refer to Visual Website Optimizer’s privacy policy: https://vwo.com/privacy-policy/. If you do not want Visual Website Optimizer to collect your usage behavior, you can object to the data collection using this link. https://vwo.com/opt-out/

Amplitude

Our app uses the analytics service Amplitude, provided by Amplitude, Inc. 501 2nd Street, Suite 100 San Francisco, CA 94107, USA. Interactions with the app are stored and subsequently evaluated for analysis purposes. For this purpose, device information such as installation ID, IP address, and information about your user behavior is processed. Diese Daten werden dann an die Server des Dienstanbieters in den USA übertragen. For more information about Amplitude, please see Amplitude’s privacy policy: https://amplitude.com/privacy.

Sendgrid

This website uses SendGrid to send newsletters. The provider is SendGrid, Inc, 1801 California Street, Suite 500, Denver, CO 80202, USA.

SendGrid is a service with which, among other things, the sending of newsletters can be organized and analyzed. The data you enter for the purpose of receiving the newsletter will be stored on SendGrid’s servers in the USA.

If you do not want SendGrid to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in each newsletter message. Furthermore, you can also unsubscribe from the newsletter directly on the website.

Data analysis through SendGrid
With the help of SendGrid, we are able to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links, if any, were clicked. In this way, we can determine, among other things, which links were clicked on particularly often.

In addition, we can see whether certain previously defined actions were performed after opening/clicking (conversion rate). We can thus recognize, for example, whether you have visited our website after clicking on the newsletter.

SendGrid also allows us to subdivide (“cluster”) the newsletter recipients based on various categories. In doing so, newsletter recipients can be subdivided by age, gender or place of residence, for example. In this way, the newsletters can be better adapted to the respective target groups.

For detailed information on SendGrid features, please refer to the following link: https://sendgrid.com/solutions/email-marketing/

Legal basis
The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time. The legality of the data processing operations already carried out remains unaffected by the revocation.

Storage period
The data you have provided us with for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of SendGrid after you unsubscribe from the newsletter. Data that has been stored by us for other purposes remains unaffected by this.

For more details, please refer to SendGrid’s privacy policy at: https://sendgrid.com/policies/security/.

Conclusion of a contract for order processing
We have concluded a contract with SendGrid in which we oblige SendGrid to protect our customers’ data and not to pass it on to third parties. This contract can be viewed at the following link: SendGrid Data Processing Addendum

Payment services
We integrate payment services from third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, account details, credit card number) is processed by the payment service provider for the purpose of processing the payment. For these transactions, the respective contract and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6 para. 1 lit. b DSGVO (contract processing) and in the interest of a smooth, convenient and secure payment process (Art. 6 para. 1 lit. f DSGVO). Insofar as your consent is requested for certain actions, Art. 6 para. 1 lit. a DSGVO is the legal basis for data processing; consents can be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

PayPal
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.

For details, see PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Apple Pay
The provider of the payment service is Apple Inc, Infinite Loop, Cupertino, CA 95014, USA. Apple’s privacy policy can be found here: https://www.apple.com/legal/privacy/de-ww/.

Google Pay
The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google’s privacy policy can be found here: https://policies.google.com/privacy.

Singular

a) Description and scope of data processing
We use mobile tracking technologies. For this purpose, we use the services of Singular Labs, Inc, 181 South Park Street, Unit 2, San Francisco, CA 94107, USA. With the help of these services, we collect statistical data about the use of our services in order to constantly improve our services. As part of the use of our apps or websites, information that your end device transmits to us is collected and analyzed. The following data is collected: anonymized IP address, anonymized Apple ID for advertising (IDFA) or Google advertising ID (GAID) as well as geographical location information, data on the behavior and usage patterns of end users of mobile apps. There is no direct personal reference. The data collected in this way is used to create anonymous usage profiles. The data collected using tracking technology is not used to personally identify the user of our services without the separately granted consent of the person concerned. For more information, please see Singular Labs’ privacy policy at: https://www.singular.net/privacy-policy.
b) Legal basis for data processing
The legal basis for this processing is Art. 6(1)(f) DSGVO. We have entered into a contract for commissioned processing with Singular Labs….

c) Purpose of the data processing.
The purpose is to improve your user experience with our services and to be able to make our offer more attractive to you. In addition, the collected data is used to analyze the performance of marketing campaigns and to create performance reports.

d) Duration of storage
The data will be stored by us for the duration of your use of the service. Singular Labs will retain your inquiry, analytics and contact information for as long as necessary for business purposes, and thereafter for as long as necessary for record retention.

e) Opt-out and opt-out options
Data collection and storage can be stopped at any time with effect for the future by adjusting the settings of your mobile device as explained above at IX.5. You may also object or request deletion of your data from Singular Labs by contacting them at privacy@singular.net
contacting them at.

Google Analytics
We use Google Analytics, a web analytics service provided by Google LLC (“Google”), on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with IP anonymization activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The users’ personal data is deleted or anonymized after 14 months.
Google Universal Analytics
We use Google Analytics in the form of “Universal Analytics”. “Universal Analytics” refers to a method of Google Analytics in which user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”).
Target group formation with Google Analytics
We use Google Analytics to display the ads placed by within advertising services of Google and its partners, only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences”, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of users.
Google AdWords and conversion measurement
We use the services of Google AdWords on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) lit. f. DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our Online Offerings in a more targeted manner to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she has expressed interest on other online offers, this is referred to as “remarketing”. For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information about the use of the online offer.

Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that personally identifies users.

The users’ data is processed pseudonymously within the Google advertising network. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about the users is transmitted to Google and stored on Google’s servers in the USA.

For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

We use the so-called “TikTok pixel” of the provider TikTok (for EU: TikTok Information Technologies UK Limited, Aviation House, 125 Kingsway Holborn, London, WC2B 6NH.) on this website. This is a code which we have implemented on our site. With the help of this code, in the case of your explicit consent, a connection is established with the TikTok servers when you visit our website, in order to track your behavior on our website. For example, when you purchase a product on our website, the TikTok pixel is triggered and stores your actions on our website in one or more cookies. You have the option to revoke your consent at any time with effect for the future. There are no costs for this other than the basic rates.

Personal data such as the IP address and other information such as device ID, device type and operating system may also be transferred to TikTok. TikTok uses email or other login or device information to identify users of our website and associate their actions with a TikTok user account.

TikTok uses this data to display targeted and personalized advertising to its users and to create interest-based user profiles. The collected data is anonymous and not visible to us and is only used to measure the effectiveness of ad placements.

In principle, your data will be processed within the EU or the EEA. For this purpose, a corresponding data protection agreement has been concluded with TikTok. If personal data is transferred to countries outside the EU or EEA, this is done within the framework of the Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses).

Here you can find TikTok’s privacy policy: https://www.tiktok.com/legal/page/us/privacy-policy/en/

Facebook-Pixel, Custom Audiences und Facebook-Conversion

Within our online offer, due to our legitimate interests in analysis, optimization, and economic operation of our online offering, we use what is known as the “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of Facebook pixel, it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use Facebook pixel to ensure that our Facebook ads are only displayed to Facebook users who have shown an interest in our online offer, or who exhibit certain characteristics (e.g. interests in certain topics or products determined by their browsing behavior), which we transmit to Facebook (known as “Custom Audiences”). With the help of Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not come across as bothersome. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

The processing of data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook ads, in Facebook’s data usage policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook Pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

You can opt out of the Facebook Pixel’s collection and use of your data to display Facebook Ads. To set which types of ads are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are done in a platform-independent manner, which means that they are applied to all devices, such as desktop computers or mobile devices.

You can further object to the use of cookies used for reach measurement and advertising purposes via the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

Online presence in social media
We maintain an online presence within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing policies of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.
Integration of third-party services and content
Within our online offer, we use content or service providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offers from third party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always requires that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.
Youtube
We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.
LinkedIn
Within our online offer, functions and contents of the service LinkedIn, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy. LinkedIn is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Vaia, Briennerstrasse 59, 80333 Munich, Germany (hereinafter referred to as Vaia), operates the learning platform www.hellovaia.com Users can upload their individual learning materials on the learning platform and share content they have created themselves, such as index cards and notes, as well as information with other users. In addition, users have the opportunity to find out about potential employers and other offers from our advertising partners.

Vaia values your privacy and the collection, processing and use of user data is in accordance with the German Data Protection Act, in particular the German Federal Data Protection Act as well as the German Telemedia Act and our Privacy Policy.

During registration on the Vaia platform, users must agree to the Terms and Conditions and Privacy Policy. Consent can be revoked at any time if Vaia is notified of this by sending an email to info@hellovaia.com.

We store and process the following data on the Vaia platform.

1. Static user data

Users are asked to provide personal data during the registration process. Users provide the following data during the registration process: First name, last name, email address, username, password, study program.

Additionally, users have the option to provide the following data in the profile section of Vaia: Date of birth, Gender.
The username, first name and degree program may be visible to others as part of community features.

News and changes to Vaia policies are communicated to our users via email. In addition, users are informed via email about selected offers from advertising partners. Users can unsubscribe from the Vaia newsletter and other offers at any time by sending an email to info@hellovaia.com.

2. External services and plugins

a) Vaia uses the “Google Analytics” service, which is provided by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), to analyze website usage by users. The service uses “cookies” – text files that are stored on the user’s terminal device. The information collected by the cookies may be sent to a Google server in the USA and stored there.

IP anonymization is used on this website. The IP address of the user is shortened within the member states of the EU and the European Economic Area. This shortening eliminates the personal reference of your IP address. Under the terms of the commissioned data agreement which the website operators have concluded with Google Inc., the latter uses the information collected to evaluate website use and website activity and provides services associated with internet use.

As a result of using the Vaia platform, the user agrees to the above-described data storage and processing by Google Analytics. Users have the option to prevent the cookie from being stored on your device by making appropriate settings in your browser. It is not guaranteed that you will be able to access all functions of this website without restrictions if your browser does not allow cookies. Google Analytics can also be disabled by a browser add-on provided by Google Inc. at http://tools.google.com/dlpage/gaoptout?hl=en.

Here you can find more information about the use of data by Google Inc.: https://support.google.com/analytics/answer/6004245?hl=de

b) This offer uses Google AdSense, a service for embedding advertisements of Google Inc (“Google”). Google AdSense uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. Google AdSense also uses so-called web beacons (invisible graphics). Through these web beacons, information such as visitor traffic on the pages of this offer can be evaluated.
The information generated by cookies and web beacons about the use of this website (including the IP address of users) and delivery of advertising formats will be transmitted to and stored by Google on servers in the United States. This information may be passed on by Google to contractual partners of Google. However, Google will not merge your IP address with other data stored by you.

Users may refuse the use of cookies by selecting the appropriate settings on their browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, users consent to the processing of data about them by Google in the manner and for the purposes set out above.

c) This offer uses the “+1″ button of the social network Google Plus, which is operated by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). The button is recognizable by the “+1″ sign on a white or colored background.

When a user calls up a website of this offer that contains such a button, the browser establishes a direct connection with the servers of Google. The content of the “+1″ button is transmitted by Google directly to his browser and integrated by it into the website. the provider therefore has no influence on the scope of the data that Google collects with the button. According to Google, no personal data is collected without a click on the button. Only for logged-in members, such data, including the IP address, are collected and processed.

The purpose and scope of the data collection and the further processing and use of the data by Google, as well as your rights in this regard and setting options for protecting your privacy, can be found in Google’s data protection information on the “+1″ button: http://www.google.com/intl/de/+/policy/+1button.html and the FAQ: http://www.google.com/intl/de/+1/button/.

d) This offer uses social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins are recognizable by one of the Facebook logos (white “f” on blue tile or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

When a user calls up a website of this offer that contains such a plugin, his browser establishes a direct connection with Facebook’s servers. The content of the plugin is transmitted by Facebook directly to your browser, which then integrates it into the website. The provider therefore has no influence on the scope of the data that Facebook collects with the help of this plugin and therefore informs users according to its level of knowledge:

By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in the privacy notices of Facebook: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him/her via this offer and link it to his/her membership data stored on Facebook, he/she must log out of Facebook before visiting the website.

Further settings and objections to the use of data for advertising purposes, are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

e) Remarketing tags of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA are integrated on our pages. When you visit our pages, the remarketing tags establish a direct connection between your browser and the Facebook server. Facebook thereby receives the information that you have visited our site with your IP address. This allows Facebook to associate the visit to our pages with your user account. We can use the information obtained in this way to display Facebook Ads. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Facebook. For more information on this, please refer to Facebook’s privacy statement at https://www.facebook.com/about/privacy/ . If you do not wish to have data collected via Custom Audiences, you can deactivate Custom Audiences at https://www.facebook.com/settings/?tab=ads.

f) With your consent, we use the “visitor action pixel” of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) within our website. With its help, we can track the actions of users after they have seen or clicked on a Facebook ad. This allows us to track the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, which means that we do not see the personal data of individual users. However, this data is stored and processed by Facebook, about which we inform you according to our level of knowledge. Facebook may associate this data with your Facebook account and also use it for its own advertising purposes, in accordance with Facebook’s Data Use Policy https://www.facebook.com/about/privacy/. You may allow Facebook and its partners to serve ads on and off Facebook. It may further store a cookie on your computer for these purposes. This consent may only be given by users who are over 13 years old. If you are younger, please ask your parent or guardian for guidance. You may revoke your consent at http://www.youronlinechoices.com/uk/your-ad-choices.

g) This website uses Hotjar, an analytics software provided by Hotjar Ltd (“Hotjar”) (http://www.hotjar.com, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, Europe). With Hotjar it is possible to measure and analyze the usage behaviour (clicks, mouse movements, scroll heights, etc.) on our website. The information generated by the “tracking code” and “cookie” about your visit to our website is transmitted to the Hotjar servers in Ireland and stored there. The following information is collected by the tracking code:

Device dependent data
The following information may be recorded by your device and browser:

Your device’s IP address (collected and stored in an anonymized format).
Your email address, including your first and last name, if you provided it to us through our website
Screen size of your device
Device type and browser information
Geographic location (country only)
The preferred language to display our website
User interactions
Mouse events (movement, position and clicks)
Keystrokes

Log data
The following data is automatically generated by our servers when Hotjar is used

Referring domain
Visited pages
Geographic location (country only)
The preferred language to display our website
Date and time when the website was accessed

Hotjar will use this information to evaluate your use of our website, generate usage reports, and provide other services related to website usage and internet evaluation of the website. Hotjar also uses third-party services, such as Google Analytics and Optimizely, to provide services. These third-party companies may store information that your browser sends as part of your website visit, such as cookies or IP requests. For more information on how Google Analytics and Optimizely store and use data, please refer to their respective privacy statements.

By continuing to use this website, you consent to the aforementioned processing of data there by Hotjar and its third-party providers under their privacy policies.

The cookies that Hotjar uses have different “lifetimes”; some remain valid for up to 365 days, and some remain valid only during the current visit.

You can prevent the collection of data by Hotjar by clicking on the following link and following the instructions there: https://www.hotjar.com/opt-out

3. cookies
The Vaia server log stores information transmitted by the browser about the user when visiting the Vaia platform.
– Type and version of browser, language settings and operating system
– IP address of the user
– Time, date and transferred data
– Web page from which the user accesses Vaia

4. platform content
Platform content describes uploaded documents, posts and comments on Vaia. Vaia will not share Platform Content with third parties, but it may be accessed by other users. Users have the right to determine what content they make available to others, if this is technically supported by the Vaia platform.

5. data use
Vaia uses data to operate the platform and provide all functionalities. The data is used by Vaia as follows
a) Emails: Vaia uses the email addresses of its users to send newsletters containing offers from the Vaia platform and corresponding advertising partners. Users can unsubscribe from the newsletter at any time.
b) Usage data: User data is used by Vaia to improve the Vaia Platform. Vaia reserves the right to analyze user data to compare learning time and progress.
Users have the option to delete their account at any time by sending an email to info@hellovaia.com or by mail. Users must provide the following information to do so: First Name, Last Name, Email, Address and a confirmation of identity (valid ID copy).
After deletion, there is a possibility that the user account will continue to exist for several days for technical reasons. Vaia will try to delete the account as soon as possible.

6. external links
There are external links on the Vaia platform over which Vaia has no control. Vaia assumes no liability or responsibility for links to third-party websites.

7. third party service
Vaia protects the privacy of its users. As a matter of principle, personal data is not passed on to third parties. If necessary for the operation of the platform, data is passed on to third-party providers, in particular for the provision of the user experience. This could be the case, for example, when linking to third-party platforms or integrating third-party content and services into the Vaia platform.

8. changes and consent
Vaia reserves the right, without notice, to change the Privacy Policy at any time. The current version can be accessed via the platform and users will be informed of changes via an email. In addition, users will be automatically notified of the changes the first time they log in after the privacy policy change.

9. data protection officer
Our data protection officer can be reached at support@hellovaia.com Vaia, Briennerstrasse 59, 80333 Munich, Germany

If the user does not object to the change within 2 weeks of being notified of the change, this will be deemed to be consent to the changed data protection statement. Vaia will inform users of the consent periods. If new consents are required, Vaia will obtain permission beforehand.