Privacy Policy

Effective Date: February 1, 2024

1. Scope
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These General Terms and Conditions (hereinafter referred to as "Terms") govern the contractual relationship between ELEVEL Academy (hereinafter "ELEVEL") and the users and companies (hereinafter "Customers") who use the online platform www.elevel.io (hereinafter "Platform").

2. Services Provided by ELEVEL

2.1 ELEVEL offers on-demand courses created by renowned lecturers and made available by ELEVEL. These courses are generally accessible to users free of charge.
2.2 Companies have the opportunity to target their audience and present themselves as attractive employer brands or general brands by sponsoring courses.
2.3 Additionally, companies can purchase licenses to further educate their employees with the content of the ELEVEL Academy, unlocking all content in the employer's branding.

3. Registration and Use
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3.1 The use of certain services on the Platform requires registration. By registering, the customer accepts these Terms.
3.2 ELEVEL reserves the right to refuse registrations without giving reasons.
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4. Collaboration with Lecturers
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4.1 Agreement with Lecturers
Lecturers offering courses on the ELEVEL platform enter into a specific agreement with ELEVEL that details rights, duties, and compensation. This agreement includes provisions on the quality of the course content, currency of the teaching materials, and interaction with the users of the Platform.
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4.2 Quality Assurance
Lecturers commit to offering high-quality courses that meet the standards and guidelines of ELEVEL. ELEVEL reserves the right to regularly review course content to ensure it meets quality requirements. Lecturers are encouraged to keep their courses up to date and make necessary updates to ensure the accuracy and relevance of the content.
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4.3 Handling User Feedback and Complaints
Lecturers are required to take constructive feedback and complaints from users seriously and respond appropriately. ELEVEL provides a mechanism for users to direct feedback and complaints about the courses directly to ELEVEL. ELEVEL will review this feedback and any complaints and work with lecturers to find a satisfactory solution.
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4.4 Rights to Course Content
Lecturers grant ELEVEL the necessary usage rights to the course content they create, including, but not limited to, the right to reproduce, distribute, make publicly available, and edit, as necessary for the provision and promotion of the courses on the Platform. This grant of rights is typically non-exclusive unless otherwise agreed.
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4.5 Responsibilities
Lecturers are solely responsible for complying with all applicable laws and regulations regarding the content they provide, including copyright and data protection. ELEVEL assumes no liability for illegal content or actions of lecturers.

4.6 Termination of Collaboration
The specific conditions for terminating the collaboration between ELEVEL and the lecturers are set in the lecturers-agreement. Both parties commit to respecting the rights of the other party upon termination, especially regarding the use and ownership of the course content.

5. Copyright and Usage Rights
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5.1 Ownership and Copyright
All course content on the Platform, including, but not limited to, texts, graphics, videos, interactive modules, and other materials, are copyrighted and owned by ELEVEL, the lecturers, or third parties. The use of these contents by users and companies is subject to the defined rights of use and restrictions.
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5.2 Usage Rights for Users
Users are granted a non-exclusive, non-transferable, personal license to access and use the course content for personal or professional development purposes. Any further use, especially the reproduction, distribution, public performance, or modification of the contents, is prohibited without prior written consent from ELEVEL or the respective copyright owners.
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5.3 Usage Rights for Companies
Companies that purchase licenses for the education of their employees are granted the right to use the course content within the agreed license terms. This use is limited to internal use for employee training. Any use of the course content for commercial purposes, especially for training purposes outside the company or the distribution of content to third parties without prior written consent from ELEVEL, is expressly prohibited.

5.4 Restrictions

Users and companies may not use the Platform and its contents to:Download, copy, or distribute materials unless expressly permitted.Use content in a way that could infringe the copyright, trademark rights, or other intellectual property rights of ELEVEL, lecturers, or third parties.Use automated systems or software to extract data from the Platform for commercial purposes ("scraping").

5.5 Protection of Intellectual Property
Users and companies acknowledge that the course contents and all associated intellectual property rights exclusively belong to ELEVEL, the lecturers, or the respective licensors. The use of the Platform and its contents does not grant users and companies any rights to these intellectual property rights other than the explicitly granted rights of use.

5.6 Responsibility for Violation
In case of violation of the rights of use and restrictions, ELEVEL reserves the right to block the respective user accounts or to take legal action to protect the rights of ELEVEL, lecturers, or third parties.

6. Usage Rights for Companies
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6.1 Under the license agreement, companies are granted the right to use selected courses for the education of their employees. These rights are non-transferable and intended for internal use only.
6.2 Companies commit not to use the Platform and its contents for commercial training purposes outside the agreed framework.

7. Responsibilities of Users
7.1 Users are responsible for securing their account details and for all activities that occur under their account. Furthermore, users are responsible for the accuracy of their provided data.
7.2 Users commit to not using the Platform for illegal activities and to respect the rights of other users, lecturers, and third parties.

8. Compensation and Payment Terms
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8.1 Compensation for sponsoring courses and purchasing licenses is based on the prices valid
at the time of booking.
8.2 Details of the payment terms will be communicated to the customer at the time of booking.

9. Liability
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9.1 ELEVEL is not liable for content provided by third parties, including external lecturers and companies.
9.2 ELEVEL is liable according to statutory provisions for the technical availability and functionality of the Platform.

10. Data Protection
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10.1 ELEVEL commits to complying with data protection laws and processing personal data of users only within the scope of legal provisions.
10.2 Details on data protection are described in the Platform's privacy policy.

11. Termination and Account Deletion
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11.1 ELEVEL reserves the right to terminate or deactivate user accounts in case of violation of the Terms, unlawful behavior, or upon request of the user.
11.2 Users and companies can have their accounts deleted at any time, with certain data being retained for legal reasons or for the settlement of open transactions.

12. Conflict Resolution
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12.1 Objective of Conflict Resolution
ELEVEL values the satisfaction of our users and companies highly. Should disagreements or complaints arise in connection with the use of the Platform or the services offered, ELEVEL aims for a quick and amicable resolution of these conflicts.

12.2 Contact in Case of Complaints
Users and companies are asked to first contact ELEVEL's customer service with their complaints by using the contact address provided under point 9. ELEVEL commits to promptly processing complaints and seeking a fair and satisfactory solution for both sides.

12.3 Alternative Dispute Resolution
If direct conflict resolution is not possible, users and companies have the option to turn to an independent arbitration board. ELEVEL will inform upon request about the responsible arbitration board and participate in an out-of-court arbitration procedure, if offered and sensible.

12.4 Legal Proceedings
The possibility of initiating legal proceedings to resolve disputes remains unaffected. The use of the procedures described in the Terms for conflict resolution is not to be understood as a prerequisite for taking legal action.

13. Cancellation Conditions for Branding Measures

13.1 General Conditions
Companies have the right to cancel services under certain conditions. Cancellations must be made in writing and are valid from the date the cancellation request is received by ELEVEL.

13.2 Cancellation Period
Companies can cancel a service without cancellation fees up to 14 days before the scheduled start of the campaign. For cancellations that occur later, cancellation fees apply, based on the extent of work already performed and costs incurred.

13.3 Cancellation Fees
13.3.1 Calculation of Fees
The amount of cancellation fees depends on the timing of the cancellation and the degree of work already performed for the campaign. A cancellation less than 14 days before the campaign start incurs 50% of the agreed costs. Cancellation after the campaign start incurs 100% of the agreed costs.

13.4 Exceptions
13.4.1 Force Majeure
In the event of force majeure, making it impossible for a company to carry out the campaign as planned, special cancellation conditions may be agreed upon. This requires written consent from ELEVEL.
13.4.2 Performance Disturbances
In the case of proven performance disturbances clearly attributable to ELEVEL, the company has the right to terminate the contract without cancellation fees. This assumes that ELEVEL was previously given a reasonable period to remedy the disturbance and this period has passed without success.

13.5 Cancellation Process
13.5.1 Execution
To cancel a campaign, the company must send a written notification to ELEVEL, stating the reasons for the cancellation. The notification should include the campaign name, the planned start date, and a detailed justification for the cancellation.

14. License Agreement and Cancellation Conditions for Internal Training

14.1 Companies that purchase licenses for the use of digital content for their employees agree that these licenses are valid from the moment of activation of the content for the agreed period. The specific conditions of the license period and use will be set at the time of purchase. ELEVEL will then activate all licenses purchased on the start date specified by the company. The distribution of the activated licenses is usually the responsibility of the company itself.
14.2 Cancellation before activation: Companies can cancel the purchase of licenses without cancellation fees up to 24 hours before the planned activation. Cancellation requests must be sent in writing to info@elevel-academy.de.
14.3 Cancellation after activation: After the activation of the licenses, cancellation of the purchase and a refund of the costs is generally not possible. However, ELEVEL recognizes that under certain circumstances (e.g., non-fulfillment of agreed services), an adjustment of the conditions may be necessary. In such cases, ELEVEL asks the affected companies to contact them to find a mutual solution.
14.4 These license conditions are in accordance with applicable laws and regulations. If there are specific legal requirements for your company, we recommend consulting with a legal advisor before purchasing the licenses.

15. Adjustments to the Terms and Conditions

15.1 ELEVEL reserves the right to update or change these Terms and Conditions at any time without prior notice. Changes to the Terms and Conditions become effective as soon as they are published on our platform.
15.2 We commit to informing our users and companies at least 30 days before the entry into force of significant changes to the Terms and Conditions via email or through a clearly visible notification on our platform.
15.3 Continued use of our services by the user after the changes come into effect constitutes acceptance of the updated or changed Terms and Conditions. If you do not agree with the changed conditions, you are free to discontinue the use of the platform and the associated services.

16. Final Provisions

16.1 Should individual provisions of these Terms and Conditions be invalid, the validity of the remaining provisions remains unaffected.
16.2 The contractual relationship between ELEVEL and the customer is subject to the law of the Federal Republic of Germany. The place of jurisdiction is Stuttgart.

17. Contact

For questions about these Terms and Conditions or the platform, customers can contact info@elevel-academy.de.

1. Introduction

In the following, we inform about the processing of personal data when using

our website https://www.elevel.io/
of our profiles in social media.
Personal data is any data that can be related to a specific natural person, e.g.
their name or IP address.
1.1. Contact details
The responsible person according to Art. 4 para. 7 EU General DataProtection Regulation (DSGVO) is Tobias Kruse & Max Middelhauve GbR, Seidenstraße 57, 70174 Stuttgart, Germany, e-mail: info@elevel-academy.de. We are legally represented by Tobias Kruse & Max Middelhauve.
Our data protection officer is the:
heyData GmbH
Kantstr. 99, 10627 Berlin www.heydata.eu
Email: datenschutz@heydata.eu.
1.2. Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. The following are generally considered to be the legal basis for data processing:
Art. 6 para. 1 p. 1 it. a DSGVO serves as our legal basis for processing operations for which we obtain consent.
We collect and process personal data from users primarily for the purpose of matching them with companies interested in sponsoring their education. This process is essential for providing our specialized matching service. The legal basis for this processing is Art. 6 para. 1 p. 1 lit. b DSGVO (GDPR), as the processing of personal data is necessary for the performance of a contract to which the user is party. This includes scenarios where users engage with our platform to be matched with potential sponsors. This legal basis also applies to processing necessary for pre-contractual measures, such as user inquiries and assessments to determine their eligibility for sponsor matching. In situations where we require specific data to effectively perform this matching service, such data will be appropriately marked as required. Failure to provide such necessary data may hinder our ability to successfully match users with potential sponsoring companies. Users may also choose to provide additional, voluntary information. The provision of this extra data is based on the user's consent, in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO. We advise users to refrain from including sensitive personal data, such as information about political opinions, religious beliefs, or other similar data, in their profiles or communication with us, unless it is deemed relevant and necessary for the sponsorship matching process. If such sensitive data is provided, its processing will be based on the user's consent, in accordance with Art. 9 (2) a DSGVO. Furthermore, we may process user data for future sponsorship opportunities or other related services if the users have given us explicit consent to do so. In such cases, the legal basis for processing remains Art. 6 para. 1 p. 1 lit. a DSGVO.
Art. 6 (1) p. 1 lit. c DSGVO applies if we fulfill a legal obligation with the processing of personal data, as may be the case, for example, in tax law.
Art. 6 (1) p. 1 lit. f DSGVO serves as the legal basis when we can invoke legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.
1.3. Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside of the EEA, the security of the data during the transfer is guaranteed, insofar as(e.g. for the UK, Canada and Israel) available, by adequacy decisions of theEU Commission (Art. 45 Ab. 3 DSGVO).
If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer is usually, i.e., unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 (2) lit.b DSGVO, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that protect the data beyond the standard contractual clauses. These are
e.g. guarantees regarding the encryption of data or regarding an obligation of the third party to notify data subjects when law enforcement bodies want to access data.
1.4. Storage duration
Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for reasons of commercial or tax law.

1.5. Rights of the data subjects

Data subjects have the following rights vis-à-vis us with regard to the personal data concerning them:

Right to information,
Right to rectification or deletion,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Right to revoke consent given at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details for the data protection supervisory authorities are available athttps://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.
1.6. Obligation to provide data
In the context of a business relationship or other relationship, customers, interested parties or third parties only have to provide us with the personal data that is required for the establishment, implementation and termination of the business relationship or for the other relationship, or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory information is marked as such.
1.7. No automatic decision making in individual cases For the establishment and implementation of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 DSGVO. Should we use these procedures in individual cases, we will inform about this separately if this is required by law.

1.8. Contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g.names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6para. 1 p. 1 lit. f DSGVO) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

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

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest lies in direct advertising (recital 47 DSGVO). Customers can object to the use of their e-mail address for advertising purposes at anytime without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address. Based on the consent of the recipients (Art. 6 para. 1 p. 1 lit. a DSGVO), we also measure the opening and click-through rate of our newsletters to understand which content is relevant to our recipients.

We send newsletters using the Mailchimp tool from the provider RocketScience Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA30308, USA (privacy policy: https://mailchimp.com/legal/privacy/). The provider processes content, usage, meta/communication data and contact data in the USA.

3. Data processing on our website

3.1. Informational use of the website

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

These data are:

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

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

3.2. Web hosting and provision of the website

Our website hosts Webflow. The provider is Webflow, Inc., 398 11th St.,Floor 2, San Francisco, CA 94103, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the USA. Further information can be found in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

It is our legitimate interest to provide a website, so that the legal basis of the described data processing is Art. 6 para. 1
S. 1 lit. f DSGVO is.

We use the Cloudflare content delivery network for our website. The provider is Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA. The provider thereby processes the personal data transmitted via the website, e.g.content, usage, meta/communication or contact data in the USA. For more information, please refer to the provider's privacy policy athttps://www.cloudflare.com/de-de/ privacypolicy/.

We have a legitimate interest in using sufficient storage and delivery capacities to ensure optimal data throughput even during large load peaks.The legal basis of the described data processing is therefore Art. 6 para. 1 p. 1lit. f GDPR.

Standard data protection clauses guaranteed (Art. 46 para. 2 lit. c DSGVO),which we have agreed with the provider.

3.3. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.

We delete the data accruing in this context after the storage is no longer required or restrict the processing if there are legal retention obligations.

3.4. Data Processing for Matching Users with Sponsor Companies

We collect and process personal data from users primarily for the purpose of matching them with companies interested in sponsoring education for individuals in specific fields or areas of study. The processing of this data is carried out to facilitate the matching process, which is a core function of our service.

The legal basis for this processing is Art. 6 para. 1 p. 1 lit. a DSGVO (GDPR), as it is necessary for the performance of a contract to which the user is party, or in order to take steps at the request of the user prior to entering into a contract. In cases where we require specific data to effectively match users with sponsoring companies, such data will be appropriately marked as required, and we will explain the necessity of this data. Failure to provide such necessary data may hinder our ability to successfully match users with potential sponsors.

In addition to the required data, users may choose to provide additional voluntary information. Providing this additional data is based on the user's consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO.

We advise users to avoid including sensitive personal data, such as information about political opinions, religious beliefs, or other similar data, unless they deem it relevant and necessary for the purpose of the educational sponsorship. In instances where users provide such sensitive data, its processing will be based on the consent of the users in accordance with Art. 9 (2) a DSGVO.

Furthermore, we may process user data for future sponsorship opportunities or other related services if the users have given us explicit consent to do so. In such cases, the legal basis for processing is also Art. 6 para. 1 p. 1 lit. a DSGVO.

3.7. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter"technically necessary cookies"), the legal basis for the associated data processing is Art. 6 para. 1

S. 1 lit. f DSGVO. We have a legitimate interest in providing customers and other site visitors with a functional website. Specifically, we set technically necessary cookies for the following purpose or purposes:

Cookies that store the shopping cart,
Cookies that payment providers set for payment processing and do
not analyze user behavior and
Flash cookies set to play media content
3.8. Conducting seminars and forwarding your data to partner companies
When you register for a free webinar on our website, we first process you rregistration data to manage your registration and provide the access data.The legal basis for data processing is Art. 6 (1) lit. b DSGVO. Furthermore, we use your email address to inform you about further webinars and events.The legal basis for this data processing is your consent according to Art. 6para. 1 lit. a DSGVO.
As part of your registration, we will forward the contact information provided during registration (name, phone number, and professional status provided)to one of our partner companies who will
you can view here. Our partner companies use this information to obtain feedback on the respective webinar and to present their own services. The use is based on consent in accordance with Art. 6 para. 1 lit. a DSGVO.
If you revoke your advertising consent to ELEVEL, we will also notify the partner companies involved of this revocation.
In addition, you as the affected party can also contact the respective partner company individually.

3.9. Third-party supplier

3.9.1. Google Tag Manager

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

We delete the data when the purpose for collecting it no longer applies.Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en.

3.9.2. Zapier

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

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in easily connecting the applications in our company and thus optimizing the way we work. The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

We delete the data when the purpose for collecting it no longer applies.Further information is available in the provider's privacy policy at https://zapier.com/privacy.

3.9.3. Webflow

We use Webflow to create websites. The provider is Webflow, Inc., 39811th St., Floor 2, San Francisco, CA 94103, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in theUSA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.

We delete the data when the purpose for collecting it no longer applies.Further information is available in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

3.9.4. Google Conversion Tag

We use Google Conversion Tag for conversion tracking. The provider isGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA. The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/ privacy?hl=enhttps://support.google.com/tagmanager/answer/9323295?hl=en&ref_topic=3441532.

3.9.5. Facebook Conversion API

We use Facebook Conversion API for analysis. The provider is MetaPlatforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider. The data is deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.facebook.com/ policy.php.

3.9.6. HubSpot

We use HubSpot to manage customer relationships. The provider isHubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in managing data in a simple and inexpensive way. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data is deleted when the purpose for which it was collected no longer applies and there are no retention obligations to the contrary. Further information is available in the provider's privacy policy athttps://legal.hubspot.com/ privacy-policy.

3.9.7. Mailchimp

We use Mailchimp for email marketing and email management. The provider is Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000,Atlanta, GA 30308, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms), contact data (e.g. email addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the USA.

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

3.9.8. Paddle

We use Paddle for payments. The provider is Paddle.com Market Limited, 15Briery Close, Great Oakley, Corby, Northamptonshire, NN18 8JG, UnitedKingdom. The provider processes content data (e.g. entries in online forms),payment data (e.g. bank details, invoices, payment history) and meta/communication data (e.g. device information, IP addresses) in the UK.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in maintaining a structured overview of our revenue.

Legal basis of the transfer to a country outside the EEA are adequacy decisions. The security of the data transferred to the third country (i.e. a country outside the EEA) is ensured because the EU Commission has decided, within the framework of an adequacy decision pursuant to Article 45(3) of the GDPR, that the third country offers an adequate level of protection.

3.9.9. Elfsight

We use Elf sight to integrate widgets. The provider is SP Iusupov A.A.. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) .

Legal basis of the transfer to a country outside the EEA are adequacy decisions.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the Privacy policy of the provider available at https://elfsight.com/privacy-policy/.

3.9.10. Google Analytics

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

3.9.11. Typeform

We use Typeform for questionnaires and forms. The provider is Typeform S.L., 163 Carrer de Bac de Roda, Barcelona, Spain. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g.device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country(i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2)of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

We use Airtable for data management and organization. The provider is Formagrid, Inc., doing business as Airtable, with headquarters at 799 Market Street, Suite 400, San Francisco, CA 94103, USA.

Airtable processes usage data (e.g., records of interactions with our services), content data (e.g., data entries in tables and forms), contact data (e.g., email addresses, phone numbers), and meta/communication data (e.g., device information, IP addresses) in the USA.

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

We use Memberstack for membership management and authentication services. The provider is Memberstack, Inc., with its address at Memberstack Inc. 1209 Orange Street, Wilmington, New Castle County, Delaware 19801, USA.

Memberstack processes usage data (e.g., user interactions with our membership platform), content data (e.g., entries in membership forms), contact data (e.g., email addresses, phone numbers), and meta/communication data (e.g., device information, IP addresses) primarily in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. This processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing carried out until the revocation.

The legal basis for the transfer of data to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is ensured by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

Data is deleted when the purpose for which it was collected no longer applies and there are no retention obligations to the contrary. For more information, please refer to the provider's privacy policy at https://docs.memberstack.com/hc/en-us/articles/11419812024347-Privacy-Policy.

4. Data processing on social media platforms

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

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

4.1. Facebook

We maintain a profile on Facebook. The operator is Meta Platforms IrelandLtd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. One way to object to data processing is via settings for advertisements:https://www.facebook.com/settings? tab=ads.
We are jointly responsible for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 DSGVO withFacebook. Facebook explains exactly what data is processed athttps://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, under our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

4.2. Instagram

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

4.3. YouTube

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

4.4. Twitter

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

4.5. LinkedIn

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

4.6. TikTok

We maintain a presence on TikTok. The platform is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. You can find TikTok's privacy policy here: https://www.tiktok.com/legal/privacy-policy?lang=en.

As part of our TikTok presence, we may share content, communicate with followers, and participate in TikTok's broader network. TikTok may collect personal data of its users (such as interaction data and demographic information) and share it with us in aggregated or anonymized form for analytics and marketing purposes.

To manage your data on TikTok and control advertising preferences, you can adjust your settings on the platform.

5. Changes to this privacy policy

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

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us at info@elevel-academy.de

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