Name and address of the controller
1.1 The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection provisions is:
Circle Digital Holding UG
Lohmühlenstr. 65, 12435 Berlin
Commercial Register: HRB 212743 B Amtsgericht Charlottenburg
E-Mail: hi@skillzuschuss.com
1.2 Name and address of the data protection officer
1.3 The data protection officer of the controller is:
Circle Digital Holding UG
Lohmühlenstr. 65, 12435 Berlin
1.4 General information on data processing
1.5 Scope of processing of personal data
We process personal data of our users in principle only to the extent necessary to provide a functional website as well as our content and services, in particular our GrantOS software. The processing of personal data of our users is regularly carried out only after consent of the user. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.
1.6 Legal basis for processing personal data
Insofar as we obtain consent from the data subject for processing operations of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis. When processing personal data necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations necessary for the implementation of pre-contractual measures.
Insofar as processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis. In the event that vital interests of the data subject or another natural person require processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
If processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.
2. Data deletion and storage duration
The personal data of the data subject are deleted or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. Blocking or deletion of the data also takes place when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.
2.1 Provision of the website and creation of log files
2.2 Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data are collected:
- Information about the browser type and version used
- The operating system of the user
- The user's Internet service provider
- The user's IP address
- Date and time of access
- Websites from which the user's system reaches our website
- Websites that are accessed by the user's system via our website
The data are also stored in the log files of our system. This data is not stored together with other personal data of the user.
3. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.
3.1 Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.
Storage in log files is done to ensure the functionality of the website. In addition, the data serves us for technical optimization of the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
These purposes also constitute our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.
3.2 Duration of storage
The data are deleted as soon as they are no longer necessary for achieving the purpose of their collection. In the case of collecting data for the provision of the website, this is the case when the respective session has ended.
In the case of storing data in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or anonymized, so that an assignment of the calling client is no longer possible.
3.3 Possibility of objection and removal
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
4. Use of cookies
4.1 Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string that enables unique identification of the browser when the website is accessed again.
We use cookies to make our website functional. Some elements of our website require that the calling browser can be identified even after a page change.
The following data are stored and transmitted in the cookies:
- Language settings
- Log-in information
We also use cookies on our website that enable analysis of users' surfing behavior.
In this way, the following data can be transmitted:
- Entered search terms
- Frequency of page views
- Use of website functions
When accessing our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of personal data used in this context is obtained. In this context, reference is also made to this privacy policy.
4.2 Legal basis for data processing
The legal basis for processing personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a GDPR if the user has given consent.
The legal basis for processing personal data using technically necessary cookies is otherwise Art. 6 para. 1 lit. f GDPR.
4.3 Purpose of data processing
The purpose of using technically necessary cookies is to enable the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.
We need cookies for the following applications:
- Adoption of language settings
- Log-in information
The user data collected by technically necessary cookies are not used to create user profiles.
The use of analysis cookies is for the purpose of improving the quality of our website and its content. Through the analysis cookies we learn how the website is used and can thus continuously optimize our offer.
These purposes also constitute our legitimate interest in the subsequent processing of personal data according to Art. 6 para. 1 lit. f GDPR.
4.4 Duration of storage, possibility of objection and removal
Cookies are stored on the user's computer and transmitted from there to our site. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the storage of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may not be possible to use all functions of the website to their full extent.
4.5 GrantOS Software
5. Description and scope of data processing
5.1 Legal basis for data processing
The legal basis for processing data is Art. 6 para. 1 lit. a GDPR if the user has given consent.
Since registration serves the fulfillment of the contract and the implementation of pre-contractual measures, an additional legal basis for processing the data is Art. 6 para. 1 lit. b GDPR.
5.2 Purpose of data processing
Registration of the user is necessary for the fulfillment of the contract with the user or for the implementation of pre-contractual measures.
5.3 Duration of storage
The data are deleted as soon as they are no longer necessary for achieving the purpose of their collection.
This is the case for data collected during the registration process for the fulfillment of a contract or for the implementation of pre-contractual measures when the data are no longer necessary for the implementation of the contract. Even after conclusion of the contract, there may be a need to store personal data of the contractual partner in order to comply with contractual or legal obligations.
5.4 Possibility of objection and removal
Since the data are necessary for the fulfillment of the contract and for the implementation of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.
6. Rights of the data subject
If personal data concerning you are processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
6.1 Right of access
You may request confirmation from the controller as to whether personal data concerning you are being processed by us.
If such processing takes place, you may request information from the controller about the following information:
- the purposes for which the personal data are processed;
- the categories of personal data that are processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- the planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period;
- the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right to lodge a complaint with a supervisory authority;
- all available information about the source of the data if the personal data are not collected from the data subject;
- the existence of automated decision-making including profiling according to Art. 22 paras. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject.
You have the right to request information about whether personal data concerning you are transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
This right of access is limited insofar as it is likely to make the realization of statistical purposes impossible or seriously impair them and the restriction is necessary for the fulfillment of statistical purposes.