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Privacy Policy

In the following, we inform you about the processing of personal data by our company in accordance with the legal requirements - in particular the EU General Data Protection Regulation (GDPR, available at http://eur-lex.europa.eu ).

Table of contents:

1. General information
   1. Important terms
   2. Scope
   3. Responsible person
   4. Data Protection Officer
2. The data processing operations in detail
   1. General information on data processing
   2. Calling our services
   3. Participant eLearning
   4. Contact and feedback
   5. Cookies
3. Data subject rights
   1. Right to information (Art. 15 GDPR)
   2. Right to correction (Art. 16 GDPR)
   3. Right to erasure ("right to be forgotten") (Art. 17 GDPR)
   4. Right to restriction of processing (Art. 18 GDPR)
   5. Right to data portability (Art. 20 GDPR)
   6. Right of objection (Art. 21 GDPR)
   7. Right of complaint to a supervisory authority (Art. 77 GDPR)

1. General information

   In this section of the Privacy Policy, you will find information on the scope of application, the data controller, its data protection officer and data security. In addition, we explain in advance the meaning of important terms used in the privacy statement.
   

   1. Important terms

      Browser: Computer program for displaying web pages (e.g. Chrome, Firefox, Safari).
      

      Cookies: Text files that the accessed web server places on the user's computer by means of the browser used. The stored cookie information can contain both an identifier (cookie ID), which is used for recognition, and content data such as login status or information about visited web pages. The browser sends the cookie information back to the web server on subsequent, new visits to this page with each request. Most browsers accept cookies automatically. You can manage cookies using the browser functions (mostly under "Options" or "Preferences"). This allows the storage of cookies to be disabled, made dependent on your consent in individual cases or otherwise restricted. You can also delete cookies at any time

      Third countries: Countries outside the European Union (EU)
      

      GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing on personal data, on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), available here.
      

      Personal data: Any information relating to an identified or identifiable natural person. 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.

      Services: Our offers to which this privacy policy applies (see scope).
      

      Processing: Any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
      

   2. Scope

      This privacy policy applies to the following offers:

      • Docs in Clouds eLearning Portal, available in particular at elearning.docsinclouds.com,

   3. Responsible person

      The data controller - i.e. the person who determines the purposes and means of the processing of personal data - in connection with the Services is:
      
      Docs in Clouds TeleCare GmbH
      Vaalserstraße 460
      52074 Aachen
      
      CEO: Michael Czaplik
      Tel.: +49 241 / 430 04 400
      info@docsinclouds.com
      

   4. Data Protection Officer

      If you have any questions about data protection, please write us an e-mail or contact directly the person responsible for data protection in our organization:
      
      Data Protection Officer: Marian Ohligs
      Tel. +49 241 / 43 00 44 – 40
      E-Mail: mohligs@docsinclouds.com, dsb@docsinclouds.com

2. The data processing operations in detail

   In this section of the Privacy Policy, we inform you in detail about the processing of personal data within the scope of our Services. For better clarity, we structure this information according to certain functionalities of our services. During the normal use of the Services, different functionalities and thus also different processing operations may come into play one after the other or at the same time

   1. General information on data processing

      Unless otherwise specified, the following shall apply to all processing operations described below:

      1. No obligation to provide & consequences of non-provision

         The provision of personal data is not required by law or contract and you are not obliged to provide data. We will inform you during the input process if the provision of personal data is required for the respective service (e.g. by designating it as a "required field"). In the case of required data, failure to provide it will result in the relevant service not being provided. Otherwise, the non-provision may mean that we cannot provide our services in the same form and quality.

      2. Transfer of personal data to third countries

         All data is processed in Germany. There is no transmission to third countries.

      3. Hosting with external service providers

         Our data processing is carried out to a large extent using so-called hosting service providers, who provide us with storage space and processing capacity in their data centers and also process personal data on our behalf according to our instructions. It may happen with all of the functionalities mentioned below that personal data is transferred to hosting service providers. These service providers either process data exclusively in the EU or we have guaranteed an adequate level of data protection with the help of the EU standard data protection clauses (see under c.).

      4. Transmission to government authorities

         We transfer personal data to government authorities (including law enforcement authorities) if this is necessary for the fulfillment of a legal obligation to which we are subject (legal basis: Art. 6 para. 1 c) GDPR) or if it is necessary for the assertion, exercise or defense of legal claims (legal basis Art. 6 para. 1 f) GDPR).

      5. Storage duration

         The "Storage period" section indicates in each case how long we will use the data for the respective processing purpose. After this period has expired, the data will no longer be processed by us, but will be deleted at regular intervals, unless continued processing and storage is provided for by law (in particular because it is necessary for the fulfillment of a legal obligation or for the assertion, exercise or defense of legal claims) or you give us consent that goes beyond this.

      6. Data category designations

         In the next sections, the following summary category labels are used for specific types of data:

         • Account-Data: Login name and email address
         • Personal master data: First name, last name
         • Login data: Information about the service through which you have registered; timing and technical information about registration, confirmation and deregistration; data provided by you when registering.
         • Access data: Location, date and time of the visit to our service; the page from which the accessing system arrived at our site; pages accessed during use; session identification data (session ID); also the following information of the accessing computer system: anonymized Internet Protocol address (IP address), browser type and version, device type, operating system and similar technical information.
         • Profile data: Data, such as the learning progress or optional fields in the user profile
   2. Calling our services

      Below we describe how your personal data is processed when you access our services (e.g. loading and viewing the website, opening and navigating within the mobile device app).

      1. Purpose of data processing and legal basis and, if applicable, legitimate interests, storage period

         Data category	Purpose	Legal basis	Legitimate interest, if applicable	Storage duration
         Access data	Establishing connections, displaying the contents of the service, detecting attacks on our site based on unusual activity, diagnosing errors.	Art. 6 para. 1 f) GDPR	proper functioning of services, security of data and business processes, prevention of misuse, prevention of damage due to interference with information systems	90 Days

      2. Recipients of the personal data

         Receiver category	Data concerned	Legal basis	Legitimate interest, if applicable
         exclusively the Docs in Clouds TeleCare itself	Access data	Art. 6 para. 1 f) GDPR	Prevention of attacks by exploiting security gaps / vulnerabilities

   3. Participant eLearning

      In the following, we describe how your personal data is processed when you, as a participant, attend or conduct courses.

      1. Purpose of data processing and legal basis and, if applicable, legitimate interests, storage period

         Data category	Purpose	Legal basis	Legitimate interest, if applicable	Storage duration
         Account data, login data, personal master data, Profile data	Providing our services, displaying the contents of the service, detecting attacks on our site based on unusual activity, diagnosing errors.	Art. 6 para. 1 b) GDPR	Proper functioning of services, security of data and business processes, prevention of misuse, prevention of damage due to interference with information systems, improvement of our services	Duration of participation in the eLearning Portal

      2. Recipients of the personal data

         Receiver category	Data concerned	Legal basis	Legitimate interest, if applicable
         exclusively the Docs in Clouds TeleCare itself	Account data, login data, personal master data, Profile data	Art. 6 para. 1 b) GDPR;

   4. Contact and feedback

      In the following, we describe how your personal data is processed when you contact our customer service (e.g., via an online contact form or by phone) and/or participate in customer or user satisfaction surveys:

      1. Purpose of data processing and legal basis and, if applicable, legitimate interests, storage period

         Data category	Purpose	Legal basis	Legitimate interest, if applicable	Storage duration
         Account data, login data, personal master data, profile data, access data	Handling of customer inquiries and user complaints, improvement of our service	Art. 6 para. 1 b), f)	Customer loyalty, improvement of our service	1 year after completed processing of the request

      2. Recipients of the personal data

         Receiver category	Data concerned	Legal basis	Legitimate interest, if applicable
         Telephone provider	Phone number, connection data	Order processing (Art. 28 GDPR)

   5. Cookies

      Our website elearning.docsinclouds.com uses cookies:
      

      Name	Intended use
      MoodleSession	Necessary to stay logged in when switching from page to page. When you log out or exit the web browser, the cookie is automatically deleted.
      MoodleID	This cookie is for convenience and stores your login name in the web browser and remains even after logging out. The next time you visit the website, your login name is then already entered for login. You can disallow this cookie, but then you will always have to re-enter your login name.

      
      
      

3. Data subject rights

   When processing your personal data, the GDPR grants you certain rights as a data subject:

   1. Right to information (Art. 15 GDPR)

      You have the right to request confirmation as to whether personal data concerning you is being processed; if this is the case, you have the right to obtain information about this personal data and the information listed in detail in Article 15 of the GDPR.

   2. Right to correction (Art. 16 GDPR)

      You have the right to request without undue delay the rectification of any inaccurate personal data concerning you and, if necessary, the completion of any incomplete data.

   3. Right to erasure ("right to be forgotten") (Art. 17 GDPR)

      You have the right to request that personal data concerning you be deleted without undue delay, provided that one of the reasons listed in detail in Art. 17 GDPR applies.

   4. Right to restriction of processing (Art. 18 GDPR)

      You have the right to request the restriction of processing if one of the conditions listed in Art. 18 DSGVO is met, e.g. if you have objected to the processing, for the duration of the review by the controller.

   5. Right to data portability (Art. 20 GDPR)

      In certain cases, which are listed in detail in Art. 20 DSGVO, you have the right to receive the personal data concerning you in a structured, common and machine-readable format or to request the transfer of this data to a third party.

   6. Right of objection (Art. 21 GDPR)

      If data is collected on the basis of Art. 6 (1) p. 1 lit. f DSGVO (data processing for the protection of legitimate interests) or on the basis of Art. 6 (1) p. 1 lit. e DSGVO (data processing for the protection of public interest or in the exercise of official authority), you have the right to object to the processing at any time for reasons arising from your particular situation. We will then no longer process the personal data unless there are demonstrably compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

   7. Right of complaint to a supervisory authority (Art. 77 GDPR)

      Pursuant to Art. 77 DSGVO, you have the right to lodge a complaint with a supervisory authority if you are of the opinion that the processing of data concerning you violates data protection provisions. The right of complaint may be asserted in particular before a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement.