Privacy Policy

Privacy Policy

1. Introduction

This website is owned and operated by MPOWER Financing, Public Benefit Corporation (MPOWER). MPOWER is a United States company based in Delaware, and as such is subject to US privacy laws. By using any Site, you agree to our collection, use and maintenance of your information in the United States, subject to applicable US privacy and commercial law. Except as set forth below, MPOWER’s Privacy Policy can be found here.

MPOWER is committed to protecting the privacy of your personal information. As part of that commitment, we provide this policy to explain our privacy and data protection practices, including what information we collect, how we use it, and what choices you have about collection and use of your personal information. We urge you to review this entire policy. By browsing or using any of the sites listed below (each a “Site”, or collectively the “Sites”), you agree to the collection, use and disclosure of your personal information as described in this statement. The use of any Site is possible without you providing any personal data; however, if you want to access or use any services offered on our Sites, then the collection and processing of personal data will become necessary. If you do not agree to the terms of this statement or our collection of your personal information as described herein, then please do not use our Sites. You should know that MPOWER, as an international company, also strives to provide the privacy and data protection that visitors who are EU residents expect, and therefore we have adapted our privacy policy and data processing to be compliant for all visitors with the principles outlined in the General Data Protection Regulation (GDPR) promulgated by the EU and effective May 25, 2018.

As a result, this privacy policy covers all EU visitors to the following Sites:

We invite you to contact us if you have questions about this policy. You may write to us at:

MPOWER Financing, PBC
1101 Connecticut Avenue, Suite 900
Washington, DC 20036
USA

You may also email us at privacy@mpowerfinancing.com. This email address is monitored regularly by MPOWER employees trained in this privacy policy, MPOWER processes regarding data privacy, and your rights under the GDPR and other applicable data privacy laws.

As the controller, MPOWER has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through Sites. However, Internet-based data transmissions may in principle have security gaps, so absolute protection is not guaranteed.

2. Overview of MPOWER Data Collection and Privacy Principles

To ensure compliance with all applicable laws and to inform you of all of your rights, this Site specific policy is long and detailed. We believe a short summary of our most important policies is helpful, while all of the detail is available below.

  1. We do not collect, process, or share user data without your express consent, which is generally given through a check-box that clearly identifies the purpose of the data collection and directs you to this policy.
  2. We do not knowingly collect any personal information from children under the age of thirteen.
  3. We use cookies, but only in a limited way, and not in any manner that can personally identify the data subject.
  4. We collect personal data when you want to: use one of our services or register on any of our Sites to search for or inquire to a college or university or to search for scholarships; sign up to receive a newsletter or other related offers from us; request services or offers through a Site; request a quote or purchase an insurance policy through us; or contact us through a form on one of our Sites. In each such instance, we ask for consent as part of the collection process. Each of these types of collection and processing of personal data is addressed in greater detail below.
  5. Our collection and processing of personal data, such as your name, address, email address, or telephone number, shall comply with applicable law.
  6. We comply (to the extent applicable) with all data subject rights provided under US law and the GDPR, including the rights of confirmation, access, rectification, erasure, restriction of processing, and data portability, as well as the right to object and right to withdraw consent.

3. Definitions

The privacy policy and data protection declaration contains terms and definitions used in connection with the adoption of the GDPR by the European Union. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. In furtherance of this goal, we would like to first explain the terminology used.

In this data protection declaration, we use the following terms:

  1. Personal data

    Personal data means any information relating to an identified or identifiable natural person ("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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

  2. Data subject

    Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

  3. Processing

    Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  4. Restriction of processing

    Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

  5. Profiling

    Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

  6. Controller or controller responsible for the processing

    Controller or controller responsible for the processing is 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.

  7. Processor

    Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  8. Recipient

    Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union (“EU”), EU Member State, US, or other applicable law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

  9. Third party

    Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

  10. Consent

    Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. Typically on the Sites, consent is given by checking a box that describes the proposed use of the data and directs the data subject to this policy.

4. Name and Address of the Controller

Controller for the Sites is:

MPOWER Financing, PBC
1101 Connecticut Avenue, Suite 900
Washington, DC 20036 USA
Phone: 202-417-3800
Email: privacy@mpowerfinancing.com
Website: www.mpowerfinancing.com

5. Cookies

We use cookies for all Sites. Cookies are text files that are stored in a computer system via an Internet browser.

We use cookies that contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows us to know when you visited our Sites and servers and identify and differentiate you from other visitors to our Sites.

Through the use of cookies, MPOWER can provide the users of its Sites with more user-friendly services that would not be possible without cookies. The information and offers on our Sites can be optimized for each user. Cookies allow us, as previously mentioned, to recognize users of our Sites. The purpose of this recognition is to make it easier for users to utilize our website. For example, by allowing cookies visitors do not have to enter access data each time a Site is accessed.

The data subject may, at any time, prevent the setting of cookies through our websites by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you decline or deactivate our placement of cookies on your Internet browser, you may eliminate or disable certain features or functions on our Sites.

6. Collection of insurance application and purchase information

Users can initiate a purchase of international travel and health insurance policies directly through the Sites. Users can also apply for international major medical policies through the Sites. MPOWER passes the data (that you provided and we collected) directly through to our insurance company partners in order for them to process your application. MPOWER retains Personal Information which includes name, address, email, phone number, date of birth, policy number, travel dates and destinations, home country and citizenship, that is necessary so that MPOWER can provide services to you. MPOWER’s insurance partners have each confirmed their compliance with HIPAA, GDPR, and any other applicable data privacy laws, and their privacy policies are all freely available from their websites. Here is the privacy policy of our primary insurance partner,

International Student Insurance (ISI): https://www.internationalstudentinsurance.com/privacy-policy/

7. Collection of general data and information

The Sites collect data and information whenever you visit a Site. This data and information are stored in server log files. The data and information collected may include: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) website(s) from which an accessing system reaches a Site (so-called referrers), (4) sub-websites, (5) the date and time of access to a Site, (6) an Internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be available.

MPOWER uses such data and information to: (1) deliver Site content correctly; (2) optimize Site content and advertising; (3) enable and maintain the stability, viability, and security of our information technology systems and website technology; and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. MPOWER continuously monitors and analyzes that data and information for data protection and data security purposes.

8. Registration on our websites

The data subject has the possibility to register on MPOWER websites. When you register on a Site, the personal information you provide (including, but not limited to your name, address, email, home country, country of citizenship, highest education level achieved, degree sought, and area of study), as well as your IP address, and the date and time of your registration is collected and stored. We use this data to prevent the misuse of our services and Sites, and, where necessary, investigate and prosecute the criminal or improper use of a Site. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

Your registration on a Site, along with your voluntary submission of personal data, allows us to offer you Site specific content or services. You may edit or change your personal data at any time, or to have it deleted in accordance with applicable law.

In addition, we offer a “school search” through which users can search, sort, and select which colleges and universities they may be interested in. Upon your request, we will deliver your inquiry, including your personal data, to the selected college or university on your behalf. Personal data will never be shared or delivered to colleges, universities or other partners without your consent.

MPOWER shall, upon your request, tell you what personal data we have stored about you. Subject to applicable law, MPOWER shall, upon your written request, correct or erase your personal data from its records.. Please send any data requests to privacy@mpowerfinancing.com for prompt handling.

9. Subscription to our newsletters

On our Sites, users are given the opportunity to subscribe to various newsletters. Each Site and newsletter determines what personal data is collected and transmitted as part of the subscription process, however, at a minimum, all newsletter subscriptions require (1) a valid email address and (2) your registration and consent to newsletter delivery.

For all newsletter registrations, we also store your IP address, as well as the date and time of your registration.

All data and information collected when you register on a Site for any newsletter(s) will only be used to send you newsletters and other relevant email communications regarding our resources and offers. There is no other transfer of your personal data to any non-disclosed third party, except to the email service provider (ESP) we use to manage Site’s email list. Our current ESPs are Critical Impact and MailChimp. You may terminate your subscription to any of our newsletters at any time. For the purpose of unsubscribing to a newsletter, a corresponding link is found in each newsletter and other email. Once unsubscribed, MPOWER and its email service provider retains a record of your unsubscribe request.

10. Newsletter and Email Tracking

Our newsletters and emails contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an email was opened by you, and which links in the email were used by you.

We store and use the personal data collected in the tracking pixels contained in the newsletters and emails to optimize the transmission of newsletters and emails, as well as to align the content of future newsletters to your interests. Your personal data will not be passed on to third parties without your consent. You may, at any time, revoke consent to receive our newsletter(s) by unsubscribing through the link found on each newsletter or email or by sending a request to privacy@mpowerfinancing.com.

11. Contact possibility via the website

All Sites contain electronic contact forms which generate an instant communication to us. As a result, If you contact us by either email or a contact form, your personal data is transmitted by the data subject and automatically stored. We do not transfer any of this personal data to any third parties.

12. Routine erasure and blocking of personal data

We process and store your personal data of the data subject only for the period necessary to achieve the purpose of storage, as far as authorized by US or other applicable law.

13. Your Rights under GDPR (applicable to EU residents only)

  • Right of confirmation

    You have the right to obtain from us confirmation as to whether or not your personal data is being processed. If you wish to exercise this right, please send us an email request at privacy@mpowerfinancing.com.

  • Right of access

    You have the right to know what personal data about you. We store this data and you have a right to receive a copy of this information. Furthermore, you have the right to know the following information:

    • The purposes of the processing;
    • The categories of personal data concerned;
    • The recipients or categories of recipients to whom your personal data have been or will be disclosed, in particular recipients in third countries or international organizations (if any);
    • Where possible, the period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
    • The existence of your right to request us to rectify or erase your personal data, or restrict our processing of your personal data or to object to such processing;
    • The existence of your right to lodge a complaint with a supervisory authority;
    • When the personal data we collected did not come from you, any available information as to its source;
    • The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and consequences of such processing on you.

    You have a right to know if your personal data was transferred to a third country or to an international organization. If such applies to you, you shall have the right to be informed of the appropriate safeguards relating to the transfer. If you wish to avail yourself of this right of access, you may, at any time, send a request to privacy@mpowerfinancing.com.

  • Right to rectification

    You have the right (without undue delay), to correct any inaccurate or incorrect personal data about you. Taking into account the purposes of the processing, you have the right to have your incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, send a request to privacy@mpowerfinancing.com.

  • Right to erasure (Right to be forgotten)

    You have the right request the erasure of your personal (without undue delay), and we have the obligation to erase your personal data where one of the following grounds applies, so long as no other legal obligations on us, exist:

    • Your personal data is no longer necessary with respect to purposes for which your personal data was collected or otherwise processed.
    • You withdraw your consent to our processing of your personal data in accordance with point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for such processing.
    • You object to our processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for such processing, or you object to our processing pursuant to Article 21(2) of the GDPR.
    • Your personal data was unlawfully processed.
    • Your personal data must be erased for compliance with a legal obligation of a law to which we are subject.

    If one of the aforementioned reasons applies, and you wish to request the erasure of your personal data stored by us, you may, at any time, send a request to privacy@mpowerfinancing.com.

    Where we have made your personal data public and are obliged pursuant to Article 17(1) to erase such personal data, we shall (taking account of available technology and the cost of implementation) take reasonable steps, including technical measures, to inform parties processing the personal data that you have requested erasure of any links to, or copy or replication of, your personal data processed by them, provided that such processing is not otherwise mandated or required. We will arrange the necessary measures in such individual cases.

  • Right of restriction of processing

    You have the right to to restrict our processing of your personal data where one of the following applies:

    • You contest the accuracy of your personal data, for a sufficient period to allow us to verify the accuracy of your personal data.
    • Our processing is unlawful and you oppose the erasure of your personal data and request the restriction of your personal data instead.
    • We no longer need your personal data for the purposes of our processing, but is required by you in connection with the establishment, exercise or defense of legal claims.
    • You objected to processing pursuant to Article 21(1) of the GDPR pending the verification that we have legitimate grounds to override your objection.

    If one of the aforementioned conditions is met and you request that we restrict our processing of your personal data stored by MPOWER, you may at any time send a request to privacy@mpowerfinancing.com. MPOWER will arrange the restriction of the processing.

  • Right to data portability

    You have the right to receive your personal data held by us in a structured, commonly used, and machine-readable format. You shall also have the right to transmit such data to another data controller without hindrance from us, subject to certain limitations set forth in Article 6(1) or Article 9(2) of the GDPR. Furthermore, in exercising your right to data portability, you have the right to have your personal data transmitted directly by us to another data controller, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

    In order to assert the right to data portability, You may at any time contact MPOWER by sending an email to privacy@mpowerfinancing.com.

  • Right to object

    You have the right to object, on grounds relating to his or her particular situation, at any time, to our processing of your personal data, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

    Following our receipt of your written objection, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which either override your interests, rights, and freedoms, or for the establishment, exercise or defense of our legal claims.

    If we process your personal data for direct marketing purposes, you have the right to object at any time to our processing of your personal data for such marketing. This applies to profiling to the extent that it is related to such direct marketing. In addition, you have the right (on grounds relating to his or her particular situation) to object to our processing of your personal data for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

    In order to exercise the right to object, you may contact MPOWER by sending an email to privacy@mpowerfinancing.com.

  • Automated individual decision-making, including profiling

    We do not use automatic decision-making or profiling. However, in offering insurance products that vary in their eligibility based on country of residence, travel destination and age, our insurance partners will make automated decisions as to your eligibility for their products. When they make an automated decision about you, you have the right to contest the decision, express your point of view, and to require a human review of the decision. Contact the appropriate insurance partner directly for additional information.

  • Right to withdraw data protection consent

    You have the right to withdraw your consent to processing your personal data at any time. If you wish to exercise this right to withdraw the consent, you must contact MPOWER by sending an email to privacy@mpowerfinancing.com.

14. Legal Basis

To the extent applicable to EU residents, Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of your personal data is necessary for the performance of a contract, as is the case, for example, when processing operations are necessary to provide you with a service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If we are subject to a legal obligation by which the processing of your personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of your personal data may be necessary to protect your interests or those of another person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. In these cases, the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms of yours which require protection of your personal data. We consider that a legitimate interest could be assumed if you are a client of ours (Recital 47 Sentence 2 GDPR).

15. The legitimate interests

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

16. Period for which the personal data will be stored

The criteria used to determine the period of storage of your personal data is the respective statutory retention period designated by applicable law. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

17. Changes to this Policy

We may need to modify this privacy policy from time to time to reflect our current privacy practices, so please check back to view any changes. When you register or submit your email address on any of the Sites, you acknowledge receipt of this privacy policy and agree to receive future notices about it online. We make this policy continuously available online. We will inform you of material modifications to this policy in the future by posting changes on the Sites and/or sending you an email notification where appropriate.

18. Data Privacy and Protection Provisions From Web Service Companies Like Google and Facebook

At our discretion and election, we may use generally-available third party services on our Sites, like Google Analytics, AdSense, AdWords, and Google Remarketing. We may also include links or code that integrates with Facebook, Instagram, LinkedIn, and other social media platforms, as well as other web services companies like SalesForce, MailChimp, and others. Each of these third parties has its own data protection and privacy provisions, and detailed descriptions of each third-party, the service they provide, and links to their data privacy and protection provisions are available on this page.

Third-party Data Privacy and Protection

1. Data protection provisions about the application and use of Facebook

On this website, we have integrated components of Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Meta, located at 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/ . During the course of this technical procedure, Facebook is made aware of what specific subsite of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific subsite of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then they may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/privacy/policy/ , provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

2. Data protection provisions about the application and use of Google AdSense

On this website, we have integrated Google AdSense. Google AdSense is an online service which allows the placement of advertising on third-party sites. Google AdSense is based on an algorithm that selects advertisements displayed on third-party sites to match with the content of the respective third-party site. Google AdSense allows an interest-based targeting of the Internet user, which is implemented by means of generating individual user profiles. The operating company of Google's AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google's AdSense component is the integration of advertisements on our website. Google AdSense places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Alphabet Inc. is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google AdSense component is integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google AdSense component for the purpose of online advertising and the settlement of commissions to Alphabet Inc. During the course of this technical procedure, Alphabet Inc. gains knowledge of personal data, such as the IP address of the data subject, which allows Alphabet Inc. to understand the origin of visitors and clicks and subsequently create commission settlements.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the data subject. Additionally, cookies already in use by Alphabet Inc. may be deleted at any time via a web browser or other software programs.

Furthermore, Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in web pages to enable a log file recording and a log file analysis through which a statistical analysis may be performed. Based on the embedded tracking pixels, Alphabet Inc. is able to determine if and when a website was opened by a data subject, and which links were clicked on by the data subject. Tracking pixels serve to analyze the flow of visitors on a website.

Through Google AdSense, personal data and information which also includes the IP address, and is necessary for the collection and accounting of the displayed advertisements, is transmitted to Alphabet Inc. in the United States of America. These personal data will be stored and processed in the United States of America. The Alphabet Inc. may disclose the collected personal data through this technical procedure to third parties.

Google AdSense is further explained under the following link https://www.google.com/intl/en/adsense/start/ .

3. Data protection provisions about the application and use of Google Analytics (with anonymization function)

On this website, we have integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which allows Google to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America.

These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that is generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html . Google Analytics is further explained under the following Link https://www.google.com/analytics/ .

4. Data protection provisions about the application and use of Google Remarketing

On this website, we have integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise's Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if they call up consecutive web pages, which are also members of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, for the insertion of interest relevant advertising.

The cookie is used to store personal information, such as the Internet pages visited by the data subject. Each time you visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must visit https://adssettings.google.com and make the desired settings on each Internet browser used by the data subject.

Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ .

5. Data protection provisions about the application and use of Google-AdWords

On this website, we have integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search will display, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in Google search engine results, and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated an application or sale of goods and services..

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, such as the Internet pages visited by the data subject. Each time you visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link https://adssettings.google.com and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ .

6. Data protection provisions about the application and use of LinkedIn

We have integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085 UNITED STATES..For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins . During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from email messages, SMS messages, and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy . The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy . The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy .

7. Data protection provisions about the application and use of Twitter

On this website, we have integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called “tweets” or short messages which are limited to 280 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons . During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en .

8. Data protection provisions about the application and use of YouTube

On this website, we have integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, and the ability to review and comment on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/ . During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/ , provides information about the collection, processing and use of personal data by YouTube and Google.

9. Data protection provisions about the application and use of AddThis

On this website, we have integrated components of AddThis, a utility to add share and follow buttons to website pages.

The operating company of ShareThis is the Oracle Corporation 500 Oracle Parkway Redwood Shores CA, 94065 Corporate Phone: 650-506-7000 UNITED STATES.

AddThis receives anonymous data related to the devices of the visitors but visitors have the option of providing an email address to enhance the service.

The AddThis data protection and privacy policy available at http://www.addthis.com/privacy

10. Data protection provisions about the application and use of Instagram

On this website, we have implemented code to retrieve photos from the social media site, Instagram. They will receive information about the photos you’ve viewed, plus data for their analytics and log files.

Details about the data they collect and the Instagram data protection and privacy policy information can be found at https://help.instagram.com/155833707900388

11. Data protection provisions about the application and use of Flickr

On this website, we have implemented code to retrieve photos from the social media site, Flickr. They will receive information about the photos you’ve viewed, plus data for their analytics and log files.

Details about the data they collect and the Flickr data protection and privacy policy information can be found at: https://policies.oath.com/us/en/oath/privacy/products/flickr/index.html

12. Data protection provisions about the application and use of PayEezy

On this website, we have implemented code to process credit card transactions and collect information required to process and complete those transactions.

Details about the data they collect and the PayEezy data protection and privacy policy information can be found at: https://developer.payeezy.com/privacy-policy

13. Data protection provisions about the application and use of Zendesk

On this website, we have implemented code to implement Zendesk as the Customer Relationship Management software. They will receive and store emails that you send to our customer service department for the purpose of answering inquiries and delivering comprehensive customer support.

Details about the data they collect and the Desk.com data protection and privacy policy information can be found at: https://www.zendesk.com/company/agreements-and-terms/privacy-notice/

14. Data protection provisions about the application and use of Intuit MailChimp

On this website, we have implemented code to send emails via the MailChimp mail service. They will receive information about the emails you’ve received, opened, and clicked, plus data for their analytics and log files.

Details about the data they collect and the MailChimp data protection and privacy policy information can be found at: https://www.intuit.com/privacy/statement/

15. Data protection provisions about the application and use of Critical Impact

On this website, we have implemented code to send emails via the Critical Impact mail service. They will receive information about the emails you’ve received, opened, and clicked, plus data for their analytics and log files.

Details about the data they collect and the Critical Impact data protection and privacy policy information can be found at: https://criticalimpact.com/privacy-policy/

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