Privacy Policy

1. Introduction

In the following, we provide information about the processing of personal data

when using our website https://code.berlin/
when using our profiles in social media
as a student.

Personal data comprises all data that can be related to a specific natural person, e.g., their name or IP address.

1.1. Contact Details

The Controller pursuant to Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is CODE Education GmbH, Donaustr. 44, 12043 Berlin, E-Mail: hello@code.berlin. We are legally represented by Dr. Reimar Müller-Thum.

Our Data Protection Officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2. Scope of Data Processing, Purposes of Processing, and Legal Bases

We detail the scope of data processing, purposes of processing, and legal bases below. In principle, the following are considered as legal bases for data processing:

Art. 6 para. 1 sentence 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
Art. 6 para. 1 sentence 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g., when a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing operations required for pre-contractual measures, such as inquiries about our products or services.
Art. 6 para. 1 sentence 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, under tax law.
Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests for the processing of personal data, e.g., for cookies that are necessary for the technical operation of our website.

1.3. Data Processing Outside the EEA

insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during transfer is guaranteed by adequacy decisions of the EU Commission (Art. 45 para. 3 GDPR), where available (e.g., for the UK, Canada, and Israel).

If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer is generally—unless we indicate otherwise—Standard Contractual Clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many providers have provided contractual guarantees that go beyond the Standard Contractual Clauses to protect the data further. These include, for example, guarantees regarding data encryption or a duty of the third party to notify data subjects if law enforcement authorities wish to access data.

1.4. Storage Duration

Unless expressly stated otherwise in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and provided that no statutory retention obligations stand in the way of deletion. 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 will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5. Rights of Data Subjects

Data subjects have the following rights against us regarding their personal data:

Right of access,
Right to rectification or deletion,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Right to withdraw consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6. Obligation to Provide Data

Customers, prospective customers, or third parties only need to provide us with personal data within the framework of a business relationship or other relationship that is necessary for the establishment, execution, and termination of the business relationship or other relationship, or which we are legally obliged to collect. Without this data, we will generally have to refuse the conclusion of a contract or the provision of a service or will no longer be able to execute an existing contract or other relationship.

Mandatory information is marked as such.

1.7. No Automated Decision-Making in Individual Cases

We generally do not use fully automated decision-making pursuant to Article 22 GDPR to establish and implement a business relationship or other relationship. Should we use these procedures in individual cases, we will inform you about this separately, provided this is required by law.

1.8. Contacting Us

When contacting us, e.g., via email or telephone, the data provided to us (e.g., names and email addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in answering inquiries directed to us. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

1.9. Customer Surveys

From time to time, we conduct customer surveys to better get to know our customers and their wishes. In doing so, we collect the data requested in each case. It is our legitimate interest to better get to know our customers and their wishes, so the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data once the results of the surveys have been evaluated.

1.10. Recording of Student Meetings

To obtain more details on conversations and surveys, we record interviews with our students. For this purpose, we use the service provider Otter.ai, Inc., 800 W El Camino Real Suite 170, Mountain View, CA 94040, USA. The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. a GDPR. The processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, for example by contacting us via the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

2. Newsletter

We reserve the right to inform customers who have already used our services or purchased goods electronically about our offers from time to time via email or other means, provided they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in direct marketing (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time without additional costs, for example via the link at the end of every email or by email to our email address mentioned above.

Prospective customers have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Registration takes place by selecting the appropriate field on our website, by ticking the appropriate field in a paper document, or by another clear action, whereby prospective customers declare their consent to the processing of their data, so that the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR. Consent can be withdrawn at any time, e.g., by clicking the corresponding link in the newsletter or by notifying our email address given above. The processing of data until the withdrawal remains lawful even in the event of a withdrawal.

Based on the recipients' consent (Art. 6 para. 1 sentence 1 lit. a GDPR), we also measure the opening and click rates of our newsletters to understand which content is relevant to our recipients.

We send newsletters using the tool: HubSpot from the provider HubSpot, Inc., 25 1st Street Cambridge, MA 02141, USA (Privacy Policy: https://legal.hubspot.com/de/privacy-policy ). The provider processes content, usage, meta/communication data, and contact data in the EU and the USA.

3. Data Processing on our Website

3.1. Informational Use of the Website

During the informational use of the website, i.e., if site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server to ensure the stability and security of our website. This constitutes our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

This data includes:

IP address
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2. Web Hosting and Provision of the Website

Our website is hosted by Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA (Privacy Policy: https://aws.amazon.com/de/privacy/?nc1=f_pr .). The provider processes personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data, in the EU. It is our legitimate interest to provide a website, so the legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.

3.3. Contact Form

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

3.4. Job Advertisements

We publish positions that are vacant in our company on our website, on pages connected to the website, or on third-party websites. The processing of data provided in the context of the application is carried out for the purpose of conducting the application procedure. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 BDSG (Federal Data Protection Act). We have marked the data required for conducting the application procedure accordingly or point it out. If applicants do not provide this data, we cannot process the application. Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs, and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent its processing within the framework of processing the CV or cover letter. Their processing is then also based on the applicant's consent (Art. 9 para. 2 lit. a GDPR).

Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.

We pass on applicants' data to the responsible employees of the HR department, to our processors in the area of recruiting, and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application procedure, we will only delete the data after the termination of the employment relationship. Otherwise, we delete the data at the latest six months after the rejection of an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receipt of the application.

3.5. Customer Area

Site visitors can open a customer account on our website. We process the data requested in this context for the fulfillment of the respective user contract concluded for the account, so that the legal basis for processing is Art. 6 para. 1 sentence 1 lit. b GDPR.

3.6. Google Single-Sign-On Procedure

Site visitors can log in to our website using a Single-Sign-On procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. If a site visitor logs in via the Single-Sign-On procedure, we receive information from the provider that the site visitor is logged in with the provider, and the provider receives information that the site visitor is using the Single-Sign-On procedure on our website. Depending on the site visitor's settings in their account on the provider's site, additional information may be made available to us by the provider. The legal basis for this agreement is the consent of the site visitor who logs in with us using the account (Art. 6 para. 1 sentence 1 lit. a GDPR). The provider of the procedure is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Privacy Policy: https://policies.google.com/privacy ).

3.7. Technically Necessary Cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on a site visitor's end device. Cookies help to make the offer more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website. Specifically, we set technically necessary cookies for the following purpose or purposes:

Cookies that adopt language settings
Cookies that store login data

3.8. Third-Party Providers

3.8.1. HubSpot We use HubSpot for managing customer relationships. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 02141, USA. The provider processes usage data (e.g., visited web pages, interest in content, access times), content data (e.g., entries in online forms), and meta/communication data (e.g., device information, IP addresses) in the EU and the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and cost-effective way.

The legal basis for the transfer to a country outside the EEA is Standard Contractual Clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the examination procedure under Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider.

The data is deleted when the purpose of its collection has ceased to exist and no retention obligations prevent this. Further information is available in the provider's privacy policy at https://legal.hubspot.com/privacy-policy .

3.8.2. Google Tag Manager We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., visited web pages, interest in content, access times) in the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. The processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g., by contacting us via the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

We delete the data when the purpose for its collection has ceased to exist. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de .

3.8.3. Zapier We use Zapier for automations between applications. The provider is Zapier, Inc., 548 Market St. #62411, San Francisco, CA 94104-5401, USA. The provider processes usage data (e.g., visited web pages, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in easily connecting the applications in our company and thus optimizing the workflow.

We delete the data when the purpose for its collection has ceased to exist. Further information is available in the provider's privacy policy at https://zapier.com/privacy .

3.8.4. Google Analytics We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g., visited web pages, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA.

The data is deleted when the purpose of its collection has ceased to exist and no retention obligation prevents this. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de .

3.8.5. TikTok Pixel We use TikTok Pixel for analysis and advertising. The provider is TikTok, Inc., 10100 Venice Blvd Suite 401 Culver City, CA 90232, USA. The provider processes meta/communication data (e.g., device information, IP addresses) in the USA.

3.8.6. Meta Pixel We use Meta Pixel for analysis. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g., visited web pages, interest in content, access times) and content data (e.g., data entered in a form) in the USA. The content data is deleted as soon as the matching has been carried out. This allows us to check the effectiveness of our advertising on Meta platforms.

3.8.7. WhatsApp We use WhatsApp to communicate with our customers and/or students. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes communication data (phone number, name, messages) in the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is based on consent. Data subjects can withdraw their consent at any time, e.g., by contacting us via the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

The data is deleted when the purpose of its collection has ceased to exist and there is no obligation to retain it. You can find further information in the provider's privacy policy at https://www.whatsapp.com/legal/updates/privacy-policy-eea?lang=en .

3.8.8. Superchat (Live Chat) We use Superchat as a live chat widget on our website to offer visitors a direct way to contact us. The provider is Superchat GmbH, Germany. Processed data: The provider processes meta/communication data (e.g., IP address, browser type, screen resolution, time zone, language) as well as content data (e.g., chat messages) in the EU. To restore chat sessions, data is stored in the browser's LocalStorage (Session ID, Contact Handle ID) for a maximum of 7 days. Legal basis: The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR (consent). The processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g., by contacting us via the contact details provided in our privacy policy. Storage duration: The data is deleted when the purpose of its collection has ceased to exist and no retention obligations prevent this. Further information: https://www.superchat.de/datenschutz

3.8.9. Sanity (Content Management System & CDN) We use Sanity as a Headless Content Management System (CMS) to manage and deliver our website content. The provider is Sanity AS, Tordenskioldsgate 2, 0160 Oslo, Norway. Texts, images, and other media content are delivered to your browser in an optimized manner via the Sanity Content Delivery Network (CDN).

Processed data: The provider processes usage data (e.g., IP address, browser type, access times, requested content) in the EU (Google Cloud Platform).

Legal basis: The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in the secure, fast, and stable provision of our website content.

Storage duration: The data is processed only for the duration of the request and is not stored permanently.

Further information: https://www.sanity.io/legal/privacy

3.8.10. bunny.net (Content Delivery Network) We use bunny.net as a Content Delivery Network (CDN) for the accelerated delivery of website content. The provider is BunnyCDN, Cesta Komandanta Staneta 4a, 1215 Medvode, Slovenia.

Processed data: The provider processes usage data (e.g., IP address) temporarily for the delivery of content. bunny.net anonymizes all data that could be used to identify users and does not store personal data permanently.

Legal basis: The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in the fast and reliable provision of our website content.

Further information: https://bunny.net/privacy/

3.8.11. Luma (Event Calendar) We integrate an event calendar from Luma on our website to display our events. The provider is Luma, Inc., USA.

Processed data: The provider processes usage data (e.g., IP address, browser type, visited pages, access times) and uses cookies. Luma also uses Google Analytics for visitor statistics. The data is processed in the USA.

Legal basis: The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR (consent). The processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g., by contacting us via the contact details provided in our privacy policy.

Third country transfer: The legal basis for transfer to a country outside the EEA is Standard Contractual Clauses.

Storage duration: The data is deleted when the purpose of its collection has ceased to exist and no retention obligations prevent this.

Further information: https://lu.ma/privacy

3.8.12. make.com (Automation) We use make.com (formerly Integromat) to automate business processes and connect various services. The provider is Celonis Inc. (One World Trade Center, 87th Floor, New York, NY, 10007, USA).

Processed data: The provider processes different data depending on the automation, e.g., contact data, content data, and meta/communication data. The data is processed on servers in the EU.

Legal basis: The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in the efficient automation of our business processes.

Storage duration: The data is deleted when the purpose of its collection has ceased to exist and no retention obligations prevent this.

Further information: https://www.make.com/en/privacy-notice

3.8.13. HubSpot Forms (Web Forms) We use HubSpot Forms to provide contact and registration forms on our website. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 02141, USA.

Form Script (functional): The form script (js.hsforms.net) is classified as functionally necessary and loads without prior consent. No tracking cookies are set in this process. The data entered via the form (e.g., name, email address, message) is processed to handle the request. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in providing contact options).

Tracking (subject to consent): The HubSpot tracking (hubspotutk cookie, tracking script js.hs-scripts.com) is only loaded after consent. The legal basis for this is Art. 6 para. 1 sentence 1 lit. a GDPR.

Third country transfer: The legal basis for transfer to a country outside the EEA is Standard Contractual Clauses.

Storage duration: The data is deleted when the purpose of its collection has ceased to exist and no retention obligations prevent this.

Further information: https://legal.hubspot.com/privacy-policy

4. Data Processing on Social Media Platforms

We are present on social media networks to present our company and our services there. The operators of these networks regularly process user data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising that corresponds to the users' interests on the network pages and elsewhere on the Internet. For this purpose, the network operators store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the privacy policies of the respective operators listed below. It may also be the case that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g., because the enforcement of their rights is made more difficult or state authorities access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to answer the inquiries. This constitutes our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

4.1. Facebook We maintain a profile on Facebook. The operator is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php . One way to object to data processing is via the settings for advertisements: https://www.facebook.com/settings?tab=ads . We are jointly responsible with Facebook for the processing of data of visitors to our profile pursuant to Art. 26 GDPR based on an agreement. Exactly which data is processed is explained by Facebook at https://www.facebook.com/legal/terms/information_about_page_insights_data . Data subjects can exercise their rights against both us and Facebook. However, under our agreement with Facebook, we are obliged to forward inquiries to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

4.2. Instagram We maintain a profile on Instagram. The operator is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875 .

4.3. Tiktok We maintain a profile on Tiktok. The operator is musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA. The privacy policy is available here: https://www.tiktok.com/de/privacy-policy .

4.4. YouTube We maintain a profile on YouTube. The operator is Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de .

4.5. Twitter We maintain a profile on Twitter. The operator is Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy . One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization .

4.6. LinkedIn We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https:// https://www.linkedin.com/legal/privacy-policy?_l=de_DE . One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .

5. Changes to this Privacy Policy

We reserve the right to change this privacy policy with effect for the future. A current version is available here in each case.

6. Questions and Comments

For questions or comments regarding this privacy policy, we are happy to be available via the contact details provided above.

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Privacy Policy