1. General
Personal data is information, which identifies a person or is identifiable as a person. An identifiable person would be seen as someone who can be directly or indirectly attributed to an identification, such as a name, a recognition code, a location, an online label or someone who can be identified by one or more special features such as one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. (Art.4, Para.1 DSGVO).

The Münchner Volkshochschule values the protection of personal data. The administration of personal data is completed in accordance with the Bavarian Data Protection law (BayDSG) as well as the “Telemediengesetz” (TMG). All employees of the MVHS, as well as meticulously chosen service companies, are obliged to keep all personal data private and to follow the data protection laws.

Name and contact details of the controller within the meaning of Art. 4 Para. 7 DSGVO

Responsible for the processing is 

Münchner Volkshochschule 
Einsteinstraße 28
81675 Munich
Telephone: (089) 48006-0
Email: info@mvhs.de 

For queries please contact our Data Protection representative at:

Mein-Datenschutzberater
Ralf Turban
86668 Karlshuld
Telephone: (08454) 96236-10
Email: datenschutz@mvhs.de 

Further information on the subject of data protection can also be found on the website of the Bavarian State Commissioner for Data Protection which can be reached at: 

Bavarian State Commissioner for Data Protection
Wagmüllerstrasse 18
80538 Munich

Postal address:  Postfach 22 12 19, 80502 München
Telephone: (089) 212672-0
Fax: (089) 212672-50
Email: poststelle@datenschutz-bayern.de 
Internet: https://www.datenschutz-bayern.de 

 
2. Course Booking, Online-booking, Online-registration
For the purpose of carrying out course bookings (initiation, completion, processing and reverse transactions) and for the related services (e.g. securing the correspondence between us and the customer) we will gather, save and process personal data during the ordering and booking process as well as when completing an online-booking or registration. Required details on the registration form, by online-booking or online-registration will be used for the completion of pre-contract measures and contract compliance. Hereby there is a differentiation between compulsory and voluntary data. Without the compulsory data (name, address, telephone number, email address, date of birth and proof of discount entitlement) no contract can be completed. 

The date of birth is required to ensure that you are of age, or for those under-age, to ensure appropriate conditions are met. Also for special courses such as courses for children or teenagers the date of birth may be compulsory. Your telephone number is required in order to ensure we can contact you with regards to any changes to your course details. 

The MVHS will not use personal data for the purposes of advertising or opinion polling without your consent. 

There will be no consequences of not providing voluntary data. Of course, all such data will remain anonymous and will be kept purely for statistics in order to optimize our offer. An inference to you personally is not possible. 

By providing IBAN, surname, first name and address of the account holder you can set up a direct debit mandate. If you do not provide the required bank details, a direct debit will not be set up and you will have to pay the course fees by other means.
 
After the end of the course, all participants with a registered email address will receive an email with a link to the evaluation questionnaire, which they can fill out anonymously. The legal basis for this is the underlying training contract in accordance with Art. 6 Para. 1 lit. b) DSGVO as well as our legitimate interest in quality assurance and improving the training offer and in accordance with Art. 6 Para. 1 lit. f) DSGVO. Participation is voluntary and anonymous. You can cancel the receipt of this email at any time in accordance with Art. 21 DSGVO.

Confirmation of participation / certificates will be sent to all participants by any means (email, FAX, SMS, or similar services). It is of course possible to opt out at any time. Should confirmation of participation / certificates be required through website or app, this is done via login with password. The legal basis for this is the underlying education contract in accordance with Art. 6 Para. 1 lit. b) DSGVO. 

All data provided by you will be saved electronically. The databanks and programmes may be accessed by IT service companies employed by us. The provision of data by them is neither statutorily nor contractually required.

In the online-booking and/or registration process, your data will be encrypted (SSL) and securely transmitted by means of a software. You will recognize this through the padlock symbol in the address bar of your browser. Our website is protected through technical measures against damage, destruction and unauthorized access. 

2.1 Confirmation of registration via email
We hereby inform you that when booking online, via telephone or in writing you will receive the booking confirmation unencrypted via email. As the confirmation of registration is also the invoice, your address is stated as the invoice address. Your account details, except for four numbers is shortened.

2.2 Booking with Guest Access
You can book and pay for courses without registering, via guest access. The collection of personal data will be used exclusively for the booking in question. When you book without registration, you will need to provide all details again when making a later booking. 

2.3 Booking as a Registered Participant
By registering an online account you do not have to provide your details for every booking and can see, for example, your course history.

For the first-time online registration, we will require your personal details, which will enable us to process your course booking (see no. 2). Personal information provided at a later date (eg new bank details) will also be used for the above purposes.

3. Storage Period and Deletion
On conclusion of contract your details will be deleted, unless legal obligations for record keeping are in place. In such cases, the data will be kept for up to 10 years. Your data will be disabled except for permitted/requested (postal) advertising. On revocation of the collection authorization, successful payment of course fees or at the end of a standing order period, 36 months after the last use bank details will be deleted, unless you have registered yourself in “My Account” (see no. 2.3) or have given us, by other means, the permission to save these details. 

The data you have provided as contact possibilities will be deleted as soon as the communication has come to an end, or your issues have been completely resolved as long as this data is not required for contract purposes. Data required for communication regarding legal claims will be kept until the end of the period of limitation.

4. Transfer of Data to Third Parties
To prepare course content and materials, the course leaders receive usually via the encrypted lecturer portal a list of participants, on which only your first and last name is noted, and only in exceptional cases (for example, in short-term substitution cases or for factory tours) by unencrypted e-mail. Furthermore we will only give your email address and telephone number to the course leader for preparation and provision if this is mandatory to fulfill contractual obligations. This would include making contact to make appointments for one-to-one lessons as well as for late changes to course details (eg weather changes for an excursion)

For the participation in certified examinations and tests (e.g. Cambridge or TELC language certificates, Xpert, Finanzbuchhalter, School-leaving certificates) we will send the required data to the relevant examining body. These transfers serve the contractual obligations. For the participation in integration courses we must provide your name and other required contact details to the Federal Agency for Migration and Refugees (“BAMF”). Furthermore, for nationally funded courses and others which are funded by the Job Agency a transfer of data may be required. Such transfers are based on a legal obligation.

The transfer of data to third parties may be made when necessary for the processing of contracts.

• When payment is made via a payment service (eg Visa, MasterCard etc.), your details will be passed on to the Payment Intermediary.
• Should you be in default with a payment, your details (name, address, date of birth) will be handed over to a collection service provider so that payment enforcement can be made.
• The MVHS is tied to the E-POST system of the Deutsche Post AG. Should no email address be available for the electronic delivery of the registration card, the confirmation of registration will be sent electronically and encrypted via the E-POST system. This means that the Deutsche Post AG will hand deliver it in printed form in an envelope and to your address.
• Study trips and excursions offered by third parties and MVHS affiliates are not events offered by the Münchner Volkshochschule. The general terms and conditions of the tour operator apply. The tour operator will receive name, surname, address, telephone number and email address of the registered passengers and passport details if necessary.
• Our newsletter service is provided by XQueue. 
• You can choose to receive so-called push notifications. For this purpose, we use the services of Google, Microsoft Windows and Mozilla. The terms of use of the respective push services can be viewed here:
  • Google Firebase: https://firebase.google.com/support/privacy
  • Microsoft Windows Push Notification Services: https://docs.microsoft.com/en-US/windows/uwp/design/shell/tiles-and-notifications/windows-push-notification-services--wns--overview or https://privacy.microsoft.com/en-US/privacystatement
  • Mozilla: https://support.mozilla.org/en-US/kb/push-notifications-firefox   

Details passed on may only be used by service providers to complete contractual obligations. 

Your personal data will only be passed on to third parties when we are legally obliged to do so by way of a court order or if you have provided us with permission. 
 
5. Making Contact
You can use our contact form for any enquiries; it is SSL-encrypted and therefore cannot be accessed during its transfer by third parties. 

If you send us a message via the contact form, your personal data is only saved if it is necessary for the process of your enquiry. We will handle your data in line with the regulations of the Data Protection Law and take the greatest of precautionary measures to ensure their security. You can find out about which of your data has been saved: datenschutz@mvhs.de.

Information which you send to us via electronic mail (email) can possibly be read by third parties during the transfer. We cannot generally check your identity and are unable to know who is behind an email. If you would like to send information which requires protection we would recommend you do this via the conventional postal service. 

We have a filter, as all email companies do, against unsolicited advertising (spam) this can lead to some general emails being put into the spam file and deleted. Any emails that contain a virus are automatically deleted.

6. Newsletter Distribution
The email addresses for the distribution of newsletters are saved and only used for the purpose of your subscription to the newsletter.

The newsletter is sent by the platform Maileon (maileon.com/de) from the company XQueue GmbH. The data you provide to Maileon to receive the newsletter will be stored by XQueue until you unsubscribe and are deleted from the servers of XQueue/Maileon, unless there are other storage obligations.

Online we use a so-called double-opt-in procedure. Through the double-opt-in process new subscribers of our newsletters on our website will receive a confirmation email sent to the email address provided, only when the subscriber has confirmed receipt of this email will they become a newsletter subscriber and the newsletter(s) will be sent to the email address provided. Your signature acts as permission for the receipt of a newsletter.

We do not use singler user tracking in our newsletter distribution. 

The receipt of newsletters can be cancelled at any time by the subscriber. 

You can cancel the newsletter and/or way in which your email address is used at any time, without having to provide a reason. A link for this is available in all newsletters we send out. 

You have the possibility to cancel your subscription to the MVHS Newsletter as well as Newsletter Extra or the complete newsletter service without reason and without cost.

7. Technical Implementation of the Website
Our Web-server and the Content Management System is operated by SpaceNet AG, Joseph-Dollinger-Bogen 14, 80807 Munich, https://www.space.net. 

Responsible for design, implementation and functionality of the website is Item KG, Nobelstraße 8, 49716 Meppen, http://itemkg.de      

8. Protocolling
When you open our webpages, data is transferred between your internet browser and our web server. This is not due to a specific function of our website, this data would be generated through the access to any website. The following data will be logged during communication between your internet browser and our web-server:

• Date and time
• Name of the requested file
• Page from where the file was requested
• Access status (file transferred, file not found etc.)
• Web browser and operating system used
• Complete IP address of the computer used
• Amount of data transferred

On ending the connection, the recording is also ended. The recorded data is not stored on our web-server.

• Personal details, actively provided by you during your visit to our website, will be used, saved and processed for the completion of course bookings and other related services provided by ourselves (see no. 2).

 
9. Cookies
On accessing this website, cookies (small files) will be saved onto your hard drive with a validity of 6 months. These are only used to identify you throughout your visit and future visits to our website. Cookies offer the advantage that you need not repeatedly fill in personal information. Most browser settings automatically accept cookies, however, this function can be switched off for the duration of the individual visit or permanently.

The following services are, however, only possible when cookies are allowed:

• the booking of courses via the course basket
• the login area for participants (“my account”)
• the administration of wish lists

 
10. Active Components
Javascript is used as the active component for information supply of the Münchner Volkshochschule. This can be switched off in the settings for your internet browser. Please note that switching this off can lead to restrictions in our service offer on the website www.mvhs.de.

11. Analysis Service and Evaluation of User Behaviour (Webtracking systems)
We use the open source programme Matamo (formerly Piwik) for the design as well as the optimization of our website, Matamo uses cookies (see no. 9). The cookies (including shortened IP address) are transferred to our server and saved for user analysis. Information taken from the cookie analysis is not passed on to any third parties. You can prevent the use of cookies by changing the settings in your browser software, this can, however, result in the non-function of some  areas of the website. (see no. 9)

This website also uses Google Adwords Conversion Tracking. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of Google conversion tracking, Google and we can recognize whether the user has performed certain actions. We learn the total number of users* who have clicked on our ads and what actions they have taken (conversion statistics). We do not receive any information with which we can personally identify the users. Google itself uses cookies or comparable recognition technologies for identification. The use of Google conversion tracking is based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested (e.g. consent to store cookies), the processing is based exclusively on Art. 6 (1) lit. a DSGVO; the consent can be revoked at any time. Google may process this data on servers in the USA, but will not associate it with personal data from your Google account. More information on Google conversion tracking can be found in Google's privacy policy: https://policies.google.com/privacy?hl=de.

12. Google Maps
In order to plan your way to us and your course(s), our website (especially pages which contain course details) is connected to Google Maps. The view of Google Maps is initially deactivated, to activate it, just click on the icon, Google Maps will then be activated throughout your visit. We do not gather any of this data when you use the maps, e.g. when you click on the maps and request a route plan. It is possible that Google gathers such data; please check their terms of use: http://www.google.com/intl/de_US/help/terms_maps.html 

13. Assistance software Eye-Able®
Eye-Able® is a software developed by Web Inclusion GmbH to ensure barrier-reduced access to information on the internet for all people. The necessary files such as JavaScript, stylesheets and images are loaded from an external server. Eye-Able uses the browser's local storage to save the settings when functions are activated. All settings are only stored locally and are not transferred further.

In order to prevent attacks and to provide our service in near real time, Eye-Able® uses the Content Delivery Network (CDN) of BunnyWay d.o.o. (Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia). This is used for the purpose of fulfilling contracts with our customers (Art. 6 para. 1 lit. b DSGVO) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f DSGVO). All transmitted data and servers remain in the EU at all times to enable data protection-compliant processing in accordance with DSGVO. Web Inclusion GmbH does not record or analyse personal user behaviour or other personal data at any time.

In order to ensure data protection-compliant processing, Web Inclusion GmbH has concluded commissioned processing contracts with our hosters IONOS and BunnyWay.

You can find further information in the data protection declarations:
https://eye-able.com/datenschutz/
https://www.ionos.de/terms-gtc/terms-privacy
https://bunny.net/privacy
 

14. Use of Google Translate
Google Translate is a translation programme from Google that performs the automatic translation functions on our website. The intention is to improve usability of our website.
Google Translate is a third-party provider that we cannot influence. In some cases the translations provided match the original content of this website only approximately.
We do not guarantee the accuracy, reliability or currentness of the information generated by this system. We point out that the translations are not exact and may also contain false, misleading or offensive content. We assume no liability for this. Also, it cannot be excluded that certain elements of the website cannot be translated.
Google collects, stores and processes information to improve its services. This includes information about the language used as well as browsing and online behaviour.

You can find more information about Google Translate here:
https://translate.google.com/ 
and
http://translate.google.com/manager/website/?hl=de 
and
http://www.google.com/policies/privacy/

15. Information and Rights of Cancellation
At any time you are able to receive information regarding your saved data, without the need to provide a reason and without charge. You can have the collected data blocked, amended or deleted at any time. You can cancel your consent for us to collect and use your data, without having to provide a reason. Please contact datenschutz@mvhs.de  

Your rights:

Insofar as we process personal data from you, you are entitled to the following rights:

You have the right to request information regarding the data stored about you (Art. 15 DSGVO).

If incorrect personal data is processed, you have the right to rectification (Art. 16 DSGVO).

If the legal requirements are met, you may request the deletion or restriction of processing (Art. 17 and 18 DSGVO).

If you have consented to the processing or if there is a contract for data processing and the data processing is carried out with the help of automated procedures, you may have a right to data transferability (Article 20 DSGVO).

If you have consented to the processing and the processing is based on this consent, you can revoke the consent at any time in the future. The lawfulness of the data processing carried out on the basis of the consent until the revocation is not affected. 

You have the right to object to the processing of your data at any time on grounds relating to your particular situation, if the processing is carried out exclusively on the basis of Article 6(1)(e) or (f) DSGVO (Article 21(1)(1) DSGVO).

You can revoke the consent given to us for the collection and use of data at any time without giving reasons. To do so, please contact: datenschutz@mvhs.de.

Furthermore, you have the right to lodge a complaint with the Bavarian State Commissioner for Data Protection (see no. 1 for contact details).