Preamble

The protection of your personal data is of particular concern to us whenever you visit our website (www.worklifelearn.com) or use services via our worklifelearn portal.

We process (personal) data exclusively within the framework of the legal provisions of the European General Data Protection Regulation (GDPR) and the national legal data protection provisions based thereon (in particular the Data Protection Act (DSG) and the Telecommunications Act (TKG)).

In this privacy policy, we therefore inform you about the most important aspects of data processing in connection with your use of our online service offerings. We thus offer you a detailed overview of how and why we use the data that you provide to us or that we obtain in accordance with the conditions defined here in a legal and lawful manner.

1. What is personal data?

Personal data is any information relating to an identified or identifiable natural person. Regarding Internet presences, we may obtain and process such data relating to your person for various reasons, eg:

User-generated data: When you use our website to access services provided by our company, we process and store all content that you have provided to us, e.g. online booking data for a coaching or training service via the job coaching portal, such as your email address, name, address, professional training, career aspirations, etc.
Server and web usage logs: When you use our website, we log your user behavior on our website. This includes your actions on the website, such as clicks on buttons and links, date and time of use, data throughput, information about your browser and operating system specification, etc.
Device identification numbers and IP addresses: When you visit our website, we process and store the IP addresses of your terminal devices.

2. categories of data and legal bases of processing

2.1 Operation and security of the website - overriding legitimate interest

When you visit our website, certain data is stored automatically and anonymously for system administration purposes as well as for statistical and operational security purposes. We use this data for the proper operation of our worklifelearn portal/website, in particular to detect errors and to be able to eliminate them.

The data processing in this regard is based on the legal provisions of § 96 TKG as well as Art 6 para 1 lit f DSGVO (overriding legitimate interest). Our legally permissible and legitimate concern is to ensure the operation and security of the website and the optimization of our services. For this reason, each time you access our website, your computer or end device transmits certain information to enable you to visit the website, whereby this information may vary depending on the browser and operating system used or their settings. Data may be processed as follows:

IP address
Date and time of the request
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (page/content to be retrieved)
Access status/HTTP(S) status code
Data throughput/quantity of data transmitted
Web page from which the request comes
Browser and browser settings
Operating system and its interface
Language and version of the browser software

2.2 Voluntary input (consent) and contract performance

2.2.1 User-generated data

ibis acam also collects and processes personal data if you voluntarily choose to enter data or expressly give your consent to do so. In this case, your data is therefore only collected because you wish to use one of the services offered by ibis acam (user-generated data).

The required data is processed exclusively for the implementation of the respective service and is subsequently required for the fulfillment of a contract or for the implementation of pre-contractual measures, which take place on the basis of your request (cf. Art 6 para 1 lit b DSGVO). The collected data will be treated confidentially and stored only to the extent absolutely necessary for participant administration and for the purpose of providing the respective related services, unless a longer storage period is necessary for the purpose of fulfilling a contractual or legal obligation or for the assertion or defense of legal claims.

Thus, any booking made via the ibis acam website (www.worklifelearn.com) is a conclusion of a contract. By booking a service, you agree to the General Terms and Conditions of ibis acam and take note of this Privacy Policy. In the event of a conclusion of contract, all data from the contractual relationship will be stored at the longest until the expiry of the retention period under tax law (7 years).

You give your consent in individual cases to the electronic processing of the following personal data, insofar as their collection and processing are necessary for the purpose of providing specific services via the job coaching portal:

Master data

First and last name
Title
Salutation
Gender
Residential address
Date of birth
Social security number
Birthplace
Phone number
E-mail address
Profile picture
Data on economic and social conditions
Occupation
Training
Current professional position
Career aspiration
professional interests
Personal status data (marital status, number of children)
Data on employment histories, job search histories, and records of support services.
Job vacancy data
Data on migration background
Data on the employment and personnel search behavior of employers
Customer number
Subscription number for each completed subscription
Booking code / recognition token for payment processing
Unique valid assignment code for the selected payment method at the payment service provider (payment nonce)
Personal assessments of own character strengths
Electronic communication with other portal participants

2.2.2 Assignment by the AMS or other clients

If we have been contractually entrusted by the Public Employment Service (AMS) or other public institutions to support you in integrating into the labor market, we may also process data about you provided by the AMS or the respective institution. We need this data in order to be able to support you in the best possible way in achieving the goal set with the AMS/institution (e.g. clarification of career aspirations, determination of suitable integration measures).

2.3 Overriding legitimate interest - marketing and direct advertising

2.3.1 General

ibis acam is furthermore entitled to create personal evaluations insofar as this serves the purpose of targeted customer care and marketing. In this case, the primary objectives of data processing are customer retention and customer acquisition. In this case, the corresponding data processing is carried out for the predominant, legitimate interest of ibis acam for the purposes of direct advertising (cf. Art 6 para 1 lit f DSGVO). Direct advertising is intended to promote the sale of the advertised, own services and products.

Only user data that ibis acam has at its disposal from the contractual relationship is being processed. Under no circumstances will those data be passed on to a third party (not affiliated with the group).

2.3.2 Opt-out option / revocation

You have the unrestricted option to revoke newsletter mailings at any time and each time you receive the newsletter.

3. Transmission to third parties

3.1 General

Your data may be transferred to third parties for the following reasons:

Your data may be disclosed to any employee of our company, employees of affiliated companies, but also to other (non-affiliated) companies for the purpose of data use and processing as set forth in this Privacy Policy.
A transfer may take place if we sell our company or parts thereof or assets to third parties.
Legal regulations to which our company is subject may require us to disclose your data.

A transfer may be made to the following third parties (see "Appendix . /1):

Contractors, funding bodies that assign users to us (AMS, public institutions entrusted with the implementation of labor market policy measures);
Education and training service providers who cooperate with us and offer services for us via our worklifelearn portal;
Software provider for online communication, e-learning;
potential employers or work trial and job training sites;
Payment Service Provider / Payment Service Provider;
Software providers, IT service providers of our company, web hosting providers, in order to improve our services and products.

3.2 Storage of your data - web hosting

We store your data cloud-based on servers of an external web hosting provider, which are operated at various locations in the EEA area. We take all reasonable measures in this regard to ensure that your data is used as described in this privacy policy. We use secure servers to ensure proper storage of data. Any transmission of personal data is encrypted for security reasons.

Despite high security measures misuse or unauthorized access by third parties can never be completely ruled out due to technical developments and possibilities.

As it is not possible for us to guarantee full security, you ultimately provide your information at your own risk. Where necessary, a password may be required to access areas of our website. You are entirely responsible for the security and confidentiality of the password you generate.

3.3 Use of "own" cookies and opt out possibility

Our website uses its own cookies. These are data sets that are sent from the web server to the user's browser and stored there for later retrieval. These cookies help us to recognize your browser and

thus ensure the functionality of the portal (e.g. session cookie) security (e.g. CSRF token) and improve the user experience (e.g. analytics) of our website.

Data processing is carried out on the basis of the legal provisions of Art 5 (3) ePrivacy Directive, § 96 TKG as amended and Art 6 (1) a (consent) and f (overriding legitimate interest) of the GDPR. Our concern in terms of the DSGVO (legitimate interest) is the improvement of our offer and our web presence.

No personal data is stored in our "cookies". The generated cookies have an expiration time of max. 1 month.

You can set your browser so that you are informed about the setting of cookies, decide on a case-by-case basis whether to accept them or generally exclude the acceptance of cookies. If you do not wish to use browser cookies, you can set your browser so that the storage of cookies is not accepted. If you prevent the storage of cookies, however, we would like to point out that you may not be able to use our website to its full extent. Further general information on cookies and their management can be found at www.allaboutcookies.org.

3.4 Use of "Local Storage

Local storage is an area in the user's web browser where websites can persistently store data, similar to cookies.

We currently use Local Storage to store the following information on your device:

Paypal session: If you are logged in to Paypal, an identifier for this session.

3.5 Web Analysis - Google Analytics and Opt Out Option

We reserve the right to use Google Analytics, a web analytics service provided by Google Inc. ("Google", Alphabet LLC, Mountain View, CA 94043, USA) for analysis purposes.

Google Analytics uses "cookies" (text files), which are stored on your computer/end device and enable an analysis of your use of the website.

The information generated by these cookies about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

Since the privacy of our users is important to us, your IP address is processed in abbreviated form, i.e. pseudonymized, so that direct personal reference is excluded.

The stored cookies remain active for a maximum period of 2 years.

The following cookies are set in the case of the use of Google Analytics:

Name	Term	Function
_ga	2 years	Used to distinguish users.
_gid	24 hours	Used to distinguish users.
_gat	1 minute	Used to throttle request rates.In the case of Analytics delivery by Google Tag Manager, this cookie has the name _dc_gtm_< property-id>.
AMP_TOKEN	30 seconds to 1 year	Contains a token that can be used to request a client ID from the AMP client ID service. Other possible values indicate opt-out, inflight request, or an error requesting the client ID from the AMP client ID service.
_gac_< property-id>	90 days	Contains campaign information for the user. If the user has linked his/her Google Analytics account and Google Ads, this cookie will be read by Google Ads conversion tags unless the user exercises an opt-out. For more information, see this support article.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

The consent to data collection and storage can be revoked at any time with effect for the future.

The revocation of consent can be done by installing the Google Opt-Out Browser Plugin. For more information about Google's use of cookies, please see Google's cookie documentation.

4. Use of social media / hyperlinks to third-party websites

Our website offers you the opportunity to share links to our content on social media platforms by means of so-called "social bookmarks", whereby initially no personal data is transmitted to these providers. Only when you click on one of the social media icons will data be transmitted: When you call up the website of the respective social media provider, data is automatically transmitted to the respective service provider and stored there (including in the case of US providers in the USA).

For more information on the purpose and scope of data collection and its processing by the respective social media service, please refer to the privacy statements of these providers. There you will also find further information about your rights in this regard and setting options for protecting your privacy:

Facebook: https://www.facebook.com/about/privacy
Twitter: https://twitter.com/privacy
Xing: https://www.xing.com/privacy
LinkedIn: https://www.linkedin.com/legal/privacy-policy

Each third-party website or web application that can be accessed via our portal generally has its own privacy policy to maintain. We recommend that you check the conditions defined there.

We point out that external websites are beyond our control, we have no influence on the data collected and data processing operations, nor are we aware of the full extent of data collection, the purposes and the storage periods. The operators of the linked pages or apps are solely responsible for their content. We expressly exclude any liability and/or responsibility for the handling of your data by third parties.

5. Deletion of your user profile

You can delete your user profile at any time in the "Profile screen" by tapping on "Delete my profile".

If you also have a paid subscription at this time, it will be automatically cancelled at the end of the month.

Attention: If you delete your profile, you will irrevocably lose all the data you have created. This also means that any rights, benefits, etc. can no longer be claimed.

Data collected up to that point will be treated confidentially and stored only to the extent absolutely necessary for participant administration and for the purpose of providing the respective related services for as long as this is necessary for the purpose of fulfilling contractual or legal obligations or for asserting or defending legal claims.

6. Data security

Our company takes all legally required measures to ensure the security of your personal data. We provide for current technical measures to protect your personal data against risks during data transmissions as well as against third parties gaining information about your data. In particular, our website uses encrypted transmission via HTTPS (Hypertext Transfer Protocol Secure) when you access our website at the following address: www.worklifelearn.com.

7. General and your rights

We reserve the right to change this privacy policy at any time with effect for the future, the current version is available on our website.

In principle, you are entitled to the rights of information, correction, deletion, restriction, objection and data portability, provided that the technical requirements for this exist in the individual case. For this purpose, please contact: [email protected]

If you believe that the processing of your data violates applicable provisions of data protection law or would otherwise violate your data protection rights, you may submit a complaint to the

Austrian Data Protection Authority

Barichgasse 40-42, 1030 Vienna

Phone: +43 1 52 152-0

E-mail: [email protected]

as the responsible supervisory authority.

ibis acam Bildungs GmbH

APPENDIX . /1:

For the purpose of fulfilling the contract, we cooperate with partners who process personal data for us. These are the following partners:

A1 Telekom Austria AG, Lassallestrasse 9, 1020 Vienna

ARS - Academy for Law, Taxes & Economy Seminar- und Kongress Veranstaltungs GmbH, Schallautzerstraße 2-4, 1010 Vienna

ETC - Enterprise Training Center GmbH, Modecenterstrasse 22 / Office 4 - 5th Floor, 1030 Vienna

KAOS Educational Service gGmbH, Andreas-Hofer-Strasse 44/2, 6020 Innsbruck

Stepin GmbH, Mallwitzstraße 1, 53177 Bonn, Germany

Fast Lane Institute for Knowledge Transfer GmbH, Modecenterstrasse 14/B4, 1030 Vienna

Aspire Beteiligungs GmbH, Geiselbergstraße 15-19, 1110 Vienna

After your explicit consent, we work with partners who process personal data from you:

Payment Service Provider PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24, boulevard Royal, L-2449 Luxembourg, Luxembourg (G-D), Braintree App

Blackboard International B.V., Paleisstraat 1, 1012 RB, Amsterdam, The Netherlands

Microsoft Ireland Operations Limited, 1 Microsoft Plc, Leopardstown South County Business Park Dublin 18, D18 P521 Ireland

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland