1. Application

This Privacy Policy will inform you about the type, scope and purposes of personal data processing on the websites www.charly.education (hereinafter: “charly.education”) and www.charly.media (“charly.media”, charly.education and charly.media hereinafter collectively: the “Website”) of the PlusPeter GmbH, Chausseestraße 84, 10115 Berlin, Germany, (hereinafter: “we” or“us”). We are the controller for the processing of any personal data collected by the Website, unless specified otherwise by this Privacy Policy.

2. Data Protection Officer
You may contact our data protection officer at:
Email: datenschutz@charly.education,
Tel: + 49 (0) 30 /555798821, Mail: PlusPeter GmbH, Chausseestrasse 84, 10115 Berlin, Germany.

3. Personal Data
Personal data means any information relating to an identified or identifiable natural person. This normally includes one’s name, email address and telephone number. In addition, purely technical data that may be used to identify a person is considered personal data.

4. Legal Basis for Processing Personal Data
If we obtain your consent to the processing of personal data, Article 6(1) Letter a of the EU General Data Protection Regulation (GDPR) will serve as the legal basis.

When processing personal data necessary for the performance of a contract with you, Article 6(1) Letter b GDPR will serve as the legal basis. This also applies to processing necessary for the performance of pre-contractual measures.

If processing personal data is necessary for the purpose of legal obligations to which we are subject, Article 6(1) Letter c GDPR will serve as the legal basis.

In rare cases, your or another natural person’s vital interests may require processing personal data. In this case, Article 6(1) Letter d GDPR will serve as the legal basis.

If processing is necessary for safeguarding our or a third-party’s legitimate interests and if your interests, fundamental rights and freedoms do not override our or the third party’s interests, Article 6(1)Letter f GDPR will serve as the legal basis for processing. In these cases, our legitimate interests follow from the processing purposes specified by this Privacy Policy.

5. Automated Collection of Access Data/Server Logfiles
During every access to the Website, we will automatically collect certain technical data.

This includes the:

We will process this data for the following purposes:

What is an IP address?
Every device (e.g., smartphone, tablet or PC) connected to the Internet is assigned an IP address. Which IP address this is depends on the Internet connection through which your device is connected to the Internet. This may be the IP address assigned to you by your Internet provider, e.g., when you are connected to the Internet at home via WiFi. This may also be an IP address assigned to you by your mobile network provider or the IP address of a public or private WiFi or other Internet access provider. In the currently most common form (IPv4), an IP address consists of four digit blocks separated by points. As a private user, you will normally not use a permanent IP address, since your IP address will be assigned to you by your provider temporarily (so-called “dynamic IP address”). A permanently assigned IP address (so-called “static IP address”) may be used to identify your user data.

Our Website supports IPv6 addresses. If you have an IPv6 address, you should also know: IPv6 addresses consist of eight 4-digit blocks. The first four blocks will, like the entire IPv4 address, normally be issued to private users dynamically. However, the last four blocks of an IPv6 address (the so-called “interface identifier”) will also be determined by the device you use to browse the Website. Unless configured otherwise by your operating system, the so-called MAC address will be used for this. The MAC address is a kind of serial number issued once to every IP-ready device worldwide. We will therefore not save the last four blocks of your IPv6 address. We recommend activating the so-called “Privacy Extensions” on your device to better anonymize the last four blocks of your IPv6 address.Most standard operating systems feature a “Privacy Extensions” function which, however, may not be preconfigured in every case.

6. Publicly Accessible Content
Please note that charly.education provides a platform on which you can interact with other users. All personal data added by you will be made public. Depending on your privacy settings, either no, only your selected or all users of charly.education may view this information. If you do not agree to this, you may delete content or entries through your user account at any time.

7. User Profiles
As part of user account creation for our Website, you will be asked to enter certain personal data (especially your title, first name, name, street, ZIP code, city, telephone number, email address and, possibly, other data requested by us for registration). You may view, edit and delete this data under “User Account” at any time. You may also delete your entire user account at any time.

We will collect,save and process the data stated in this Section for the entire performance of your order, including any subsequent guarantees and our services. The legal basis for this processing is Article 6(1)Sentence 1 Letter b GDPR.

Your personal data will only be transferred to third parties or disclosed otherwise if necessary for the purposes of contract performance or invoicing, if permissible by law or with your prior consent or if the transfer is necessary for the establishment, exercise or defense of legal claims and there is no reason to believe that you have an overriding interest in the non-transfer of your data. As part of order performance, e.g., the service providers (e.g., shipping companies, logisticians or printing houses) used by us will receive the data necessary for order performance. Our service providers may only use data transferred this way to perform their order-related tasks. Other use of this information is not permitted and not performed by our commissioned service providers.

8. Use of Your Data for Marketing Purposes
We may use the email address we received for your print order for direct marketing of our similar goods and services. You may object to this usage at any time by contacting us at the contact details provided in our Website’s imprint. We will also note this right to object with every such usage.

We will use your name and your address to inform you about interesting products and services of the PlusPeter GmbH (self-advertisement). For this, we will send you offers via email, Internet, mail and the charly.education and charly.scan apps. You can choose the channels through which we may contact you. Your so-called list data (name, first name, title, acad. degree, address, year of birth, professional, industry or business name and a group identifier) will be transferred to selected companies that wish to market their own services/products and to dialogue marketing agencies for marketing through the above-stated channels (external advertisement) on the basis of legal regulations. Under the EU General Data Protection Regulation which came into effect on 25 May 2018, other data in addition to so-called list data may be used and transferred for marketing purposes. For this, we will consider your interests in the exclusion of individual data for marketing purposes. You may object to the above-stated use of your data for self- and/or external advertisement purposes at any time for the future by contacting us at the contact details provided in our Website’s imprint.

Apart from that, your email address and/or telephone number will only be used for marketing purposes with your consent. You may withdraw your consent at any time for the future by contacting us at the contact details provided in our Website’s imprint.

If you do not consent to our use of your data for marketing purposes, we will be unable to offer you our sponsored Freemium Package. However, the Standard and the Premium Package will be available to you even if you do not consent to use of your data for marketing purposes or subsequently withdraw such consent.

9. Facebook Custom Audiences & Facebook pixel
To find new charly.education friends who make interesting offers to you, we will transfer your data to Facebook in encrypted and anonymized form—this allows us to make university life easier for more students. Our advertisements will especially be displayed to those to whom they are of interest. We use “Facebook Custom Audiences” for this customary marketing procedure. We will not clearly transfer your name, email address or personal information to Facebook, but will upload this data in encrypted form. This enables us to ensure that third parties cannot access your data and that you will not suffer adverse effects.

Due to the marketing tools used, your browser will automatically establish a direct connection to Facebook’s server. We have no influence on the extent and further use of the data collected by Facebook through this tool and therefore inform you to the best of our knowledge: Through use of Facebook Custom Audiences, Facebook will be informed that you opened a respective page of our Internet presence or clicked on one of our advertisements. If you are registered on a Facebook service, Facebook may assign your visit to your Facebook account. Even if you are not registered on or logged in to Facebook, the provider may learn and save your IP address and other identifiers.

To create Facebook Custom Audiences, we also use the so-called “Facebook pixel.” When visiting our Website and when you perform certain actions, the Facebook pixel will be activated and your visit or action will be reported to—in anonymized form—and registered by Facebook. Using the collected data, Facebook can tell us how successful our Website is. In a second step, which user groups may be interested in our offers will be determined. We may then advertise to these user groups as prospective buyers, so-called “remarketing.”

By agreeing to the conditions for the creation of your user account, you consent to the data processing performed by us through “Facebook Custom Audiences.” You may withdraw this consent at any time for the future by contacting us at, e.g., the email address provided in our Website’s imprint.

If you do not consent to our use of your data for marketing purposes through Facebook marketing tools, we will be unable to offer you our sponsored Freemium Package. However, the Standard and the Premium Package will be available to you even if you do not consent to use of your data for marketing purposes or subsequently withdraw such consent.

Logged-in users may disable “Facebook Custom Audiences” at:

https://www.facebook.com/settings/?tab=ads.

Further information about data processing by Facebook is provided at:

https://www.facebook.com/about/privacy.

10. Contacting Us
When contacting us (e.g., via contact form or email), your data will be saved to process your inquiry and for any follow-up questions.

11. Newsletter
On our Website, you may subscribe to a newsletter through which we will inform you about new products, offers and other marketing campaigns.

When subscribing to our newsletter, we will save your IP address and your date of subscription. We will only save this data as evidence in case a third-party misuses an email address to subscribe to our newsletter without the authorized user’s knowledge. This data will only be used to send our newsletter and will not be transferred to third parties.

You may withdraw your consent to use of your email address to send our newsletter at any time. Such withdrawal may be declared through a link in the newsletter or by contacting us at the contact details provided in our Website’s imprint.

Please note that, when sending our newsletter, we will assess your user behavior. For this assessment, newsletter emails include so-called web beacons or tracking pixels which consist of 1-pixel image files saved on our Website. Links included in our newsletter also feature this ID. For the assessment, we will link your personal data collected under Section 5 (data transferred when merely visiting our Website) and the web beacons to your email address and an individual ID.

We will use the data obtained this way to create a user profile to tailor our newsletter to your individual interests. To determine your personal interests, we will record when you read our newsletter and which of the newsletter’s links you click on. We will link this data to actions performed by you on our Website.

You may object to this tracking at any time by clicking on the separate link provided in every email or by contacting us at the email address provided in our Website’s imprint. This information will be saved for as long as you subscribe to our newsletter. After you unsubscribe, we will save your data purely statistically and anonymously. Furthermore, such tracking will not be possible if you disable image displays on your email program. In this case, our newsletter will not be fully displayed and you may be unable to use every function. If you display images manually, the above-stated tracking will be performed.

12. Cookies
Cookies are small text files saved on your device by your browser when visiting our Website. This allows individual services of a Website to “recognize” you and “remember” your settings. This serves the user friendliness of our Website (e.g., by saving login data). Cookies are also used to collect statistical data on Website usage for analysis and marketing purposes.

Some Cookies will be automatically deleted from your device when you leave our Website (so-called session cookies). Other cookies are saved for a certain period which may not exceed 2 years (persistent cookies). To offer certain services, we also use so-called third-party cookies managed by third parties. These third parties may only collect, process and use your data as part of your order and in compliance with our instructions and may especially not transfer your data.

You may influence the use of cookies. Most browsers feature an option to limit or prevent the saving of cookies. However, please note, that disabling cookies will restrict the use and, especially, the usage comfort of our services.

13. Google Analytics
This Website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics will save several “cookies” (see above) to identify your browser. Normally, the information generated by the cookies on your use of our Website will be transferred to a Google server in the US and saved there. However, we activated the IP anonymization function on this Website so that Google will first shorten your IP address in a member state of the European Union or in another state party to the Agreement on the European Economic Area. Only in exceptions will your full IP address be transferred to a Google server in the US and shortened there. Google uses this information on our behalf to assess your use of our Website, compile reports on Website activities and to perform other services related to use of our Website and of the Internet for the Website operator. The IP address transferred by your browser when using GoogleAnalytics will not be merged with other Google data. Furthermore, you may prevent the transfer of the data generated by the cookie on your Website usage (incl. your IP address) to Google and the processing of this data by Google by downloading and installing the following browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en.

For the exceptions in which personal data is transferred to the US, Google subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for use of Google Analytics is Article 6(1) Sentence 1 Letter f GDPR.

Information on the third-party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

Terms of Service: https://marketingplatform.google.com/about/analytics/terms/us/

Data protection overview: https://marketingplatform.google.com/about/

Privacy Policy: https://policies.google.com/privacy

This Website also uses Google Tag Manager. Google Tag Manager is a user management tool for our IT division that, e.g., simplifies the management of links to Google Analytics.

14. DoubleClick by Google
This Website also uses the online marketing tool “DoubleClick by Google”. DoubleClick uses cookies to display relevant advertisements to the user, improve campaign performance reports and prevent users from repeatedly being shown the same advertisements. Google uses a cookie ID to record which advertisements are displayed on which browser to prevent repeated displays. Furthermore, by using cookie IDs, DoubleClick can record so-called conversions that refer to advertisement requests. This is the case, e.g., if a user sees a DoubleClick advertisement and subsequently uses the same browser to open the advertiser’s website and make a purchase there. According to Google, DoubleClick cookies do not feature personal information.

Due to the marketing tools used, your browser will automatically establish a direct connection to Google’s server. We have no influence on the extent and further use of the data collected by Google through this tool and therefore inform you to the best of our knowledge: Through use of DoubleClick, Google will be informed that you opened a respective page of our Internet presence or clicked on one of our advertisements. If you are registered on a Google service, Google may assign your visit to your Google account. Even if you are not registered on or logged in to Google, the provider may learn and save your IP address.

You may prevent your participation in this tracking process through several ways:

  1. Through your browser settings. Especially disabling third-party cookies will prevent third-party advertisements;
  2. By disabling conversion tracking cookies by configuring your browser to block cookies from the domain “www.googleadservices.com,” https://adssettings.google.com/authenticated, though this setting will be removed when you delete your cookies;
  3. By disabling interest-based advertising of providers who are part of the self-regulation campaign “About Ads” through the link: http://www.aboutads.info/choices, though this setting will be removed when you delete your cookies;
  4. By permanently disabling cookies on your browsers Firefox, Internet Explorer or Google Chrome at: http://www.google.com/settings/ads/plugin.

Please note that disabling cookies may prevent you from fully using every function of this offer.
The legal basis for processing your data is Article 6(1) Sentence 1 Letter f GDPR. For further information about DoubleClick by Google, please see:

https://marketingplatform.google.com/about/enterprise/and for Google’s Privacy Policy: https://policies.google.com/privacy

Google subjected itself to the EU-US Privacy Shield and therefore guarantees compliance with EU data protection standards.

15. General Advertising Opt-Out
You may reach the websites of the Digital Advertising Alliance through the following link where you can declare a general opt-out for various online advertising technologies.

A German alternative to the Digital Advertising Alliance is provided at:

http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager-beta.html (German)

16. charly.scan App
Our charly.scan app allows you to scan marked advertising banners from your printed Freemium script. After scanning, you can have the app forward you to our advertising partners’ websites where you may find, e.g., brief documentaries, interesting facts, sweepstakes, assistance and offers. By scanning banners, you will receive “PlusPoints” under our bonus program which you can use to activate additional free prints.

When using the app, we will process personal data concerning you.

  1. When downloading the app, certain necessary information will be transferred to your selected app store (e.g., Google Play or Apple App Store). This data will be processed exclusively by the respective app store and therefore lies outside of our sphere of influence.
  2. When using our app, we will automatically collect data necessary for use of the App. This includes your:
    – Internal device ID
    – Operating system version
    – App version
    – Time of current, last and first access
    – Access duration
    – Location
    This data will be transferred to us automatically and saved to provide our service and its related functions to you, improve the app’s functions and service characteristics and to prevent and eliminate misuse and errors.
    This data processing is justified because (1) this processing is necessary for the performance of the contract between you, the data subject, and us under Article 6(1) Letter b GDPR for use of the app or (2) we have a legitimate interest in guaranteeing the app’s functionality and flawless operations and in offering an interest-based service in line with the market that overrides your rights and interests concerning the protection of your personal data in the sense of Article 6(1)Letter f GDPR.
  3. To use the charly.scan app, you must log in with your username. We will use this data to authenticate you when you log in.
    This data processing is justified because (1) this processing is necessary for the performance of the contract between you, the data subject, and us under Article 6(1) Letter b GDPR for use of the app or (2) we have a legitimate interest in guaranteeing the app’s functionality and flawless operations and in offering an interest-based service in line with the market that overrides your rights and interests concerning the protection of your personal data in the sense of Article 6(1)Letter f GDPR.
  4. To scan marked banners, the charly.scan app must access your cellphone camera.
    User data is processed and used to provide the service. This data processing is justified because this processing is necessary for the performance of the contract between you, the data subject, and us under Article 6(1)Letter b GDPR for use of the app.
  5. We depend on the following external service provider for the performance of our service:
    OneSignal, Inc.,411 Borel Ave Suite 512, San Mateo, CA 94402. USA.
    The provider’s Privacy Policy is available at: https://onesignal.com/privacy_policy. When opening the app, OneSignal will transfer information about the installed apps, its use, the temporary unique device ID (e.g., IDFA and the Android ID) and additional data to OneSignal and, therefore, to states outside of the European Economic Area (“EEA”) where the data will be processed. The basis for this is Article 6(1) Letter f GDPR. This processing of personal data is justified by our legitimate interest in analyzing user behavior to improve the app and offer user-friendly contents that overrides your rights and interests in the protection of your personal data in the sense of Article 6(1)Letter GDPR.

17. Electronic Payment Processes
Our web shop offers various payment methods. In many cases, account details will be transferred exclusively to a third party that, as your bank or payment services provider (e.g., PayPal), already possesses your account details.

We will process any other data provided by you to process your order. For this, we may transfer your payment details to our bank.

Due to commercial law and tax law requirements, we must save your address, payment and order data for 10 years. However, we regularly restrict the processing of such data internally, i.e., your data will only be used for compliance with legal obligations.

18. Right of Access and to Rectification, Erasure, Restriction of Processing, Data Portability and to Object
You have the right to, on request, obtain, free of charge, information about personal data concerning you that we saved. In addition, you have the right to rectification of inaccurate data, blocking and erasure of personal data concerning you, unless prevented by legal storage obligations. In addition, you may also obtain from us restriction of processing for data concerning you. You may also receive data concerning you from us. To exercise these rights, you may contact us at any time at, e.g., datenschutz@charly.education.

Furthermore, you have the right to lodge a complaint about our processing of personal data concerning you with a data protection supervisory authority. For further information, please follow this link.

19. Data Storage Duration
We will only save personal data concerning you for as long as necessary to perform the service you requested or to which you consented or for as long as necessary for the respective data processing purpose in consideration of your interests, unless required otherwise by law.

20. SSL/Encrypted Data Transfers
Your personal data will be transferred in encrypted form to prevent third-party abuse. We use so-called SSL (Secure Socket Layer) encryption for this. This is a common security technology that encrypts your personal data, incl. credit card information, login data and your payment method, during the transfer. Please note that there is no 100% security for data transferred via the Internet.

21. Validity and Changes to this Privacy Policy
This Privacy Policy is currently valid as of May 2019.

The further development of our Website and offer and changing legal or official regulations may require adjustments to our Privacy Policy. You may find and print the respectively valid Privacy Policy on our Website at any time.