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Privacy Policy of InterNations GmbH (InterNations)

for business.internations.org and the corresponding mobile applications

November 2018

Welcome to InterNations Business Solutions! The protection of your privacy and your personal data is taken very seriously and of utmost concern for InterNations.

InterNations is a community of trust. InterNations ensures highest standards for the protection of your personal data and your privacy. This Privacy Policy is designed to help you better understand how InterNations collects and deals with your personal data and information.

InterNations works hard to earn and keep your trust. Therefore, InterNations uses personal data solely to provide you with the InterNations Services. InterNations will never rent, sell, or otherwise provide personal data to any third party for advertising or for marketing purposes without your consent.

1. Responsible body

As a visitor to our website, you expect a high level of quality not only from our platform, but also from the processing of your personal data. We are responsible for the handling of your data, which we process according to your wishes and the requirements of the German and EU data protection laws. Personal data is data that identifies you or makes you identifiable. We only process personal data if this is permitted by law or if you have given your prior consent.

The responsible body for the collection and processing of personal data is:

InterNations GmbH

Schwanthalerstr. 39

80336 Munich

Germany

Tel: +49 (0)89 4613324-0

Email: info@internations.org

If you have any questions about data protection or data security, please contact our data protection officer

Herr Bernd Fuhlert

@-yet GmbH

Der Datenschutzbeauftragte der InterNations GmbH

Schloss Eicherhof

42799 Leichlingen

Germany

Email: support@internations.org

Our service providers include, for example, data centers, analysis service providers, and payment service providers. Our service providers are prohibited from processing your data for other purposes or for themselves. It is important to us that you can find out at any time from the following information which personal data is collected during your visit to our website and when ordering in our shop and how we process it afterwards.

2. Your rights in data protection and right to cancel

You have the following rights regarding the processing of personal data:

  • Right of access by the data subject to the personal data concerned
  • Right to rectification or erasure or restriction of processing
  • If the processing of your personal data is based on a weighing of interests (Art. 6 (1) (f) GDPR) or if the processing is necessary for the performance of a task which is in the public interest or is carried out in the exercise of official authority vested in the controller (Art. 6 (1) (e) GDPR), the right to object to the processing. We will inform you about this in detail in the following sections.
  • Right to data transfer
  • If the processing of your personal data is based on your consent (Art. 6 (1) (a) or Art. 9 (2) (a) GDPR), you have the right to withdraw your consent at any time. We will inform you about this in detail in the following sections.
  • Right of appeal to a supervisory authority

You have the right to object to the processing of your data at any time for reasons arising from your particular situation if the legal requirements are met. If you object to the processing of your data for advertising purposes or wish to revoke your consent, a short message to our data protection officer by email to support@internations.org or by post to InterNations GmbH, Schwanthalerstr. 39, 80336 Munich, Germany is sufficient at any time. Your data will then no longer be processed for the advertising purposes covered by the advertising objection or the revocation of consent. This does not affect the legality of the processing carried out until the objection or revocation. After your objection to the processing of your personal data for advertising purposes or the revocation of your consent, we are obliged under data protection law in accordance with the requirements of the German data protection supervisory authorities to include the necessary data (name, address, e-mail address) in our internal advertising blacklist and - only for this purpose - to permanently store (block) and use for comparison with our future advertising files. (Art. 21 (3), Art.17 (3) (b), Art.6 (1) (c) DSGVO). In this way, compliance with your advertising objection or the revocation of your consent can be permanently ensured. If you have any questions about the processing of your personal data by us, we will of course be happy to provide you with information about the data concerning you at any time. Furthermore, you have a right to correction, deletion, restriction of processing, objection, and the right to data transfer if the legal requirements are met. In all these cases, please contact our data protection officer (see contact data under item 1) at the communication addresses listed there. Finally, you have the right to complain to a competent data protection supervisory authority.

3. Processing of personal data on our website

  • Visiting our website

InterNations GmbH - as it is usual and necessary for internet pages to be used - processes so-called server log files when you visit our internet page. When our website is accessed, our web server records the domain name or the IP address of your computer, the file name, and the URL which was requested, as well as the http response code and, if applicable, the URL referring to our website (legal basis: Art. 6 (1) (b) GDPR). This procedure is technically necessary and customary to enable the use of our website. Here we are supported by our technical service providers, which we use as contract processors. The above-mentioned data is logged and used for the purpose of defense against illegal use or attempted attacks on our web server (Art. 6 (1) (f) GDPR). The data will be deleted after 60 days.

  • Google Analytics

In the context of our platform we use the functions of the web analysis service Google Analytics. Provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called "cookies". These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. The Google Analytics cookie (legal basis Art. 6 (1) (f) GDPR) is stored because of our legitimate interest in analyzing user behavior in order to optimize our website and advertising. We are supported in this by Google as a contract processor. Google will use this information for the purpose of evaluating the user's use of the website, compiling reports on website activity and providing other services to website operators relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google.

IP Anonymization: The IP anonymization function is activated on our website. Your IP address will be shortened by Google within the European Union or in a contracting state of the Agreement on the European Economic Area before transmission to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. The legal basis for a transfer of personal data is the so-called EU-US Privacy Shield.

Browser Plugin: You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. In addition, you can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and prevent Google from processing this data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Objection to data collection: You can prevent Google Analytics from collecting your data by clicking on the following link. Disable Google Analytics. An opt-out cookie is set to prevent the collection of your information on future visits to this website. For more information on how Google Analytics uses user data, please refer to Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

Data processing agreement: We have concluded an agreement with Google for data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic features of Google Analytics: This website uses the "demographic features" function of Google Analytics. This allows reports to be generated that contain information on the age, gender, and interests of website visitors. This data comes from interest-related advertising by Google and from visitor data from third parties. This information cannot be associated with any specific individual. You can deactivate this function at any time via the ad settings in your Google Account or generally prohibit Google Analytics from collecting your data as described under "Objection to data collection".

  • Hotjar

We use Hotjar, developed by Hotjar Limited, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.). This enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular a device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For more information please review the Hotjar privacy policy available under: https://www.hotjar.com/legal/policies/privacy

You can opt out to the creation of a user profile, Hotjar’s storing of data about your usage of our site, and Hotjar’s use of tracking cookies on other websites by following this opt-out link: https://www.hotjar.com/legal/compliance/opt-out

  • New Relic

We use New Relic, developed by New Relic, 101 Second Street, 15th Floor, San Francisco, CA 94105, USA, to monitor the performance of our servers as well as the client-side performance of our website. The tool collects potentially personally identifying information such as internet protocol addresses and database queries. Neither New Relic nor we will use this information to identify individual users. New Relic is fully compliant with European data protection laws and certified under the EU-US Privacy Shield. For more information, please review the New Relic privacy policy available under: https://newrelic.com/privacy

  • SurveyMonkey

InterNations uses SurveyMonkey, developed by SurveyMonkey, One Curiosity Way, San Mateo, CA 94403, USA, to conduct online surveys. Usage data as well as the information that you enter in our surveys will be stored and processed on servers in the US. SurveyMonkey is fully compliant with European data protection laws and certified under the EU-US Privacy Shield. For more information please review the SurveyMonkey privacy policy under: https://www.surveymonkey.com/mp/legal/privacy-policy/.

  • TrackJS

We use TrackJS, developed by TrackJS LLC, to keep track of JavaScript errors on our website. The tool collects potentially personally identifying information such as internet protocol addresses. Neither TrackJS nor we will use this information to identify individual users. The service is provided in compliance with EU data protection regulations using a data processing agreement. For more information, please review the TrackJS privacy policy available under https://trackjs.com/privacy

  • Salesforce

For customer care, InterNations uses the Customer Relationship Management module "Salesforce Marketing Cloud" and "Salesforce Sales Cloud" from Salesforce.com Inc., The Landmark @ One Market Street, Suite 300, San Francisco, California, CA 94105, USA. Salesforce Marketing Cloud is a database management service for user data. The data is processed in the USA. Salesforce.com has certified this service under the EU-US Privacy Shield Scheme. For more information about the Salesforce Marketing Cloud and Sales and the processed data, please visit www.salesforce.com/euen/company/privacy/

  • HubSpot

For online marketing activities, InterNations uses HubSpot, an integrated software solution that allows us to cover a wide range of aspects, including:

  • e-mail marketing (newsletter and automated e-mails, e.g., to provide downloads)
  • social media publishing and reporting
  • reporting (e.g., sources of traffic, access, etc.)
  • contact management (e.g., user segmentation and customer relationship management)
  • landing pages, blogs, and contact forms

The InterNations contact forms allow you as a visitor to the InterNations website, to find out more about InterNations, download content and share your contact and demographic information with InterNations. This information and the content of the InterNations Business Solutions website are stored on servers belonging to the InterNations software partner HubSpot. InterNations will use this information to contact you. Cookies also allows InterNations to find out which of the InterNations services might interest you. To do so, InterNations stores information about your interaction with the InterNations website, such as the documents you download, the pages you visit, and the date and time of your visit (“usage data”), as well as whether and when you have opened marketing e-mails from InterNations.

HubSpot is a US software company with offices in Berlin.

HubSpot Germany GmbH

Unter den Linden 26

10117 Berlin

Germany

  • More information on HubSpot’s privacy policy can be found under
    https://legal.hubspot.com/privacy-policy?__hstc=230861184.4bd3953ce4cbf9ab5d4c6edd18ef4ab3.1493986648400.1493986648400.1493986648400.1&__hssc=230861184.1.1493986648400&__hsfp=2592471858
  • More information about the cookies used by HubSpot can be found under
    https://knowledge.hubspot.com/articles/kcs_article/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser?__hstc=230861184.4bd3953ce4cbf9ab5d4c6edd18ef4ab3.1493986648400.1493986648400.1493986648400.1&__hssc=230861184.1.1493986648400&__hsfp=2592471858 and https://knowledge.hubspot.com/articles/kcs_article/account/hubspot-cookie-security-and-privacy?__hstc=230861184.4bd3953ce4cbf9ab5d4c6edd18ef4ab3.1493986648400.1493986648400.1493986648400.1&__hssc=230861184.1.1493986648400&__hsfp=2592471858
  • Social Media

There are no social plugins on our website, especially not the "Like" button of the social network facebook.com. We only link to our own social media profiles. If you are logged into your social media account and follow the respective link, the social network will be able to assign your visit to our website to your user account there. If you do not want your social networks to be able to assign your visit to our website to your user accounts there, you must log out of your social media accounts before clicking any of these links.

  • Contact / Inquiries

If you have any questions or requests, please do not hesitate to contact us. We process your data to answer your service requests (Art. 6 (1) (b, f) GDPR). The communication of address and telecommunication data marked as mandatory data is necessary in order to process and answer your request. The voluntary provision of further data makes it easier for us to process your enquiry. We store the information from your inquiry after answering the inquiry generally for six years, if it concerns commercial or business letters (§ 257 Abs.4 HGB, Art. 6 (1) (c) GDPR).

  • Email advertising

With your explicit consent, which can be revoked at any time, we will inform you by email about our products and campaigns such as updates and events of our platform and/or about our various product newsletters (§ 7 Abs.2 Nr.3 UWG). We process your obligatory information when granting your consent in order to send you the newsletter(s) you have chosen and to address you personally (Art. 6 (1) (f) GDPR). In order to receive certain newsletters, you must first register (see explanation under Registration). When obtaining your consent, we use the so-called double opt-in procedure online to prevent our email messages from being sent to email addresses of persons who have not requested or do not want them. Your IP address is also recorded and stored for documentation purposes in accordance with the specifications of the data protection supervisory authorities. (Art. 7 (1), Art. 6 (1) (c) GDPR). We store your data collected for advertising purposes as long as the advertising purpose exists or until we receive a revocation of your consent or your objection to the processing of your data for advertising purposes.

  • Change of purpose

If we should change the purposes of the processing in the course of the time, we will inform you by an update of these references to the data protection in advance.

  • Extended retention periods

The specified storage periods may be extended accordingly if a longer statutory or contractual storage period exists in individual cases, in particular if the data are processed for different purposes.

4. What are mandatory fields?

If certain data fields are designated as mandatory fields and/or marked with an asterisk ( * ), the provision of this data is either required by law or contract, or we need this data for the conclusion of the contract, the desired service, or the stated purpose. Of course, you also have the right to specify the data in the mandatory fields at your discretion. Failure to provide this information may result in the contract not being fulfilled by us or the desired service not being provided, or the stated purpose not being achieved.

5. Information on cookies and newsletters

  • Cookies

The InterNations GmbH website uses web analysis technologies to collect and use data for marketing and optimization purposes. These are described and explained below separately and in more detail. In the interest of clarity, we would like to explain the subject of cookies to you here. Cookies are small text files that are stored on your computer. These are used to enable the recognition of your internet browser. These data are used to create user profiles under a pseudonym. Unless you have given your separate consent, this data will not be used to identify you personally and will not be merged with personal data about the bearer of the pseudonym. IP addresses are used in this procedure only in anonymous form. We use this data exclusively to optimize our services and to tailor them to the needs of our customers. You can object to the creation of pseudonymous user profiles by setting an opt-out cookie. In addition, we use cookies to make the use of our online platform customer friendly. For this purpose, we use information about the date and duration of a visit to our website as well as the pages viewed by the visitor. Most browsers are set to automatically accept cookies. You can set your web browser so that it notifies you when cookies are set or generally rejects or restricts the setting of cookies. If you deactivate or restrict cookies using your browser, you will no longer be able to use various functions on our website. You can delete cookies stored in your web browser at any time, even automatically.

The following links will inform you about this possibility for the most frequently used browsers:

  • Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
  • Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
  • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

If you have not made or do not make any other settings, cookies, which enable and are intended to ensure the necessary technical functions, will remain on your device until you close the browser, other cookies may remain on your device for longer.

  • Newsletter as registered user

If you subscribe to our newsletter, you agree that we will regularly inform you about current offers and competitions of InterNations GmbH and interesting facts about living abroad by email and invite you to surveys. You can revoke your consent at any time, e.g. in your account settings, via the email address support@internations.org, or by clicking on the unsubscribe link in any newsletter (to unsubscribe from that newsletter). When you register for the newsletter, we record your email address, company and name for the personalized dispatch of our newsletter. You will receive a confirmation email (so-called double opt-in procedure) to confirm your consent. We will use your data until you revoke your consent.

6. Breach of obligations

In the event InterNations has good reason to believe that you have breached your obligations under Section 5 of the GTC, InterNations will review your personal data, communication, and networking to the extent as required to verify such a breach.

7. Links

InterNations may contain links to other websites. InterNations is not responsible for the privacy practices of other websites. InterNations encourages you to be aware when you leave the InterNations websites to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by InterNations.

8. Data security

We take technical and organizational security precautions to protect your personal data against accidental or intentional manipulation, loss, destruction, or against access by unauthorized persons and to guarantee the protection of your rights and compliance with the applicable data protection regulations of the EU and the Federal Republic of Germany. The measures taken should guarantee the confidentiality and integrity of your data as well as the availability and resilience of the systems and services when processing your data in the long term. They should also quickly restore data availability and access in the event of a physical or technical incident. Our security measures also include encryption of your data. All information that you enter online is technically encrypted and only then transmitted. This means that this information cannot be viewed by unauthorized third parties at any time. Our data processing and security measures are continuously improved in line with technological developments. The employees of InterNations GmbH are or will be obliged in writing to maintain confidentiality and to comply with the data protection requirements of the GDPR.

9. Changes

This Privacy Policy must be adapted from time to time to the actual circumstances and the legal situation. Please check the Privacy Policy before using our platform to keep up to date with any changes or updates.