Data Privacy Policy Zühlke Academy

Data Protection Information
for the Academy offered by

Zühlke Engineering AG

 

With the Zühlke Academy courses, Zühlke offers its employees and customers training opportunities, including training to prepare for various certifications. The Academy courses are provided by instructors who are employees of Zühlke or external instructors.

In connection with the Academy courses, the personal data of Zühlke employees as well as of external participants and instructors are processed.

Employees of Zühlke receive information about the processing of personal data relating to the Academy courses in the data protection information for Zühlke employees.

In the following, you, as an external participant or instructor, are provided with information about the controller with responsibility for processing your per-sonal data, and the controller's representatives and Data Protection Officer (section A, as well as about your rights regarding the processing of your personal data (section B).

In addition, as an external participant or instructor, you are provided with information about the processing of your personal data (section C) relating to the Academy courses.

TABLE OF CONTENTS

A...... Information on the controller 3

I.          Identity and contact details of the controller. 3

II.         Contact details of the controller’s data protection officer 3

B....... Information on the rights of data subjects. 4

I.          Right of access. 4

II.         Right to rectification. 5

III.       Right to erasure (“right to be forgotten”) 5

IV.       Right to restriction of processing. 6

V.        Right to data portability. 6

VI.       Right to object. 7

VII.     Right to withdraw consent 8

VIII.    Right to lodge a complaint with a supervisory authority. 8

C....... Information on the processing of personal data. 9

I.          Planning, organisation and execution of training and preparation of certification. 10

II.         Academy email newsletter. 15

D.           Effective date of and changes to this Data Protection Information  20 20

 

A.  Information on the controller

I.  Identity and contact details of the controller

Zühlke Engineering AG, Wiesenstrasse 10a, 8952 Schlieren, Switzerland (ZCH)

Zühlke Engineering (Austria) GmbH, Rivergate, Handelskai 92, 1200 Vienna, Austria (ZAT)

II.  Contact details of the controller’s data protection officer

Thasanee Patklom, Wiesenstrasse 10a, 8952 Schlieren (Zuerich), Switzerland, Telefon: +41 43 216 6677

B.  Information on the rights of data subjects

As a data subject, you have the following rights with regard to the processing of your personal data:

  • Right of access (Article 15 of the General Data Protection Regulation)
  • Right to rectification (Article 16 of the General Data Protection Regulation)
  • Right to erasure (“right to be forgotten”) (Article 17 of the General Data Protection Regulation)
  • Right to restriction of processing (Article 18 of the General Data Protection Regulation)
  • Right to data portability (Article 20 of the General Data Protection Regulation)
  • Right to object (Article 21 of the General Data Protection Regulation)
  • Right to withdraw consent (Article 7 paragraph 3 of the General Data Protection Regulation)
  • Right to lodge a complaint with a supervisory authority (Article 57 paragraph 1 point f of the General Data Protection Regulation)

You may contact our data protection officer (Section A.III.) for the purpose of exercising your rights.

Where applicable, you find information on any specific modalities and mechanisms which facilitate the exercise of your rights, in particular the exercise of your rights to data portability and to object, in the information on the processing of personal data in Section C of this Data Protection Information.

Below you find more detailed information on your rights with regard to the processing of your personal data:

I.  Right of access

As a data subject, you have a right to obtain access and information under the conditions provided in Article 15 of the General Data Protection Regulation.

This means in particular that you have the right to obtain confirmation from us as to whether we are processing your personal data. If so, you also have the right to obtain access to the personal data and the information listed in Article 15 paragraph 1 of the General Data Protection Regulation. This includes information regarding the purposes of the processing, the categories of personal data that are being processed and the recipients or categories of recipients to whom the personal data have been or will be disclosed (points (a), (b) and (c) of Article 15 paragraph 1 of the General Data Protection Regulation).

You can find the full extent of your right to access and information in Article 15 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

II.  Right to rectification

As a data subject, you have the right to rectification under the conditions provided in Article 16 of the General Data Protection Regulation.

This means in particular that you have the right to receive from us without undue delay the rectification of inaccuracies in your personal data and completion of incomplete personal data.

You can find the full extent of your right to rectification in Article 16 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

III.  Right to erasure (“right to be forgotten”)

As a data subject, you have a right to erasure (“right to be forgotten”) under the conditions provided in Article 17 of the General Data Protection Regulation.

This means that you have the right to obtain from us the erasure of your personal data and we are obliged to erase your personal data without undue delay when one of the reasons listed in Article 17 paragraph 1 of the General Data Protection Regulation applies. This can be the case, for example, if personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (point (a) of Article 17 paragraph 1 of the General Data Protection Regulation).

If we have made the personal data public and are obliged to erase it, we are also obliged, taking account of available technology and the cost of implementation, to take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of those personal data (Article 17 paragraph 2 of the General Data Protection Regulation).   

The right to erasure (“right to be forgotten”) does not apply if the processing is necessary for one of the reasons listed in Article 17 paragraph 3 of the General Data Protection Regulation. This can be the case, for example, if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims (points (a) and (4) of Article 17 paragraph 3 of the General Data Protection Regulation).

You can find the full extent of your right to erasure (“right to be forgotten”) in Article 17 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

IV.  Right to restriction of processing

As a data subject, you have a right to restriction of processing under the conditions provided in Article 18 of the General Data Protection Regulation.

This means that you have the right to obtain from us the restriction of processing if one of the conditions provided in Article 18 paragraph 1 of the General Data Protection Regulation applies. This can be the case, for example, if you contest the accuracy of the personal data. In such a case, the restriction of processing lasts for a period that enables us to verify the accuracy of the personal data (point (a) of Article 18 paragraph 1 of the General Data Protection Regulation).

Restriction means that stored personal data are marked with the goal of restricting their future processing (Article 4 paragraph 3 of the General Data Protection Regulation).

You can find the full extent of your right to restriction of processing in Article 18 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

V.  Right to data portability

As a data subject, you have a right to data portability under the conditions provided in Article 20 of the General Data Protection Regulation.

This means that you generally have the right to receive your personal data with which you have provided us in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from us if the processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation or on a contract pursuant to point (b) of Article 6 paragraph 1 of the General Data Protection Regulation and the processing is carried out by automated means (Article 20 paragraph 1 of the General Data Protection Regulation).

You can find information as to whether an instance of processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation or on a contract pursuant to point (b) of Article 6 paragraph 1 of the General Data Protection Regulation in the information regarding the legal basis of processing in Section C of this Data Protection Information.

In exercising your right to data portability, you also generally have the right to have your personal data transmitted directly from us to another controller if technically feasible (Article 20 paragraph 2 of the General Data Protection Regulation).

You can find the full extent of your right to data portability in Article 20 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

VI.  Right to object

As a data subject, you have a right to object under the conditions provided in Article 21 of the General Data Protection Regulation.

At the latest in our first communication with you, we expressly inform you of your right, as a data subject, to object.   

More detailed information on this is given below:

1.  Right to object on grounds relating to the particular situation of the data subject

As a data subject, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on point (e) or (f) of Article 6 paragraph 1, including profiling based on those provisions.

You can find information as to whether an instance of processing is based on point (e) or (f) of Article 6 paragraph 1 of the General Data Protection Regulation in the information regarding the legal basis of processing in Section C of this Data Protection Information.

In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

You can find the full extent of your right to objection in Article 21 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

2 . Right to object to direct marketing

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

You can find information as to whether and to what extent personal data are processed for direct marketing purposes in the information regarding the legal basis of processing in Section C of this Data Protection Information.

If you object to processing for direct marketing purposes, we no longer process your personal data for these purposes.

You can find the full extent of your right to objection in Article 21 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

​​​​​VII.   Right to withdraw consent

Where an instance of processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation, as a data subject, you have the right, pursuant to Article 7 paragraph 3 of the General Data Protection Regulation, to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal. We inform you of this before you grant your consent.

You can find information as to whether an instance of processing is based on point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation in the information regarding the legal basis of processing in Section C of this Data Protection Information.

​​​​​​​​​​​​​​VIII.  Right to lodge a complaint with a supervisory authority

As a data subject, you have a right to lodge a complaint with a supervisory authority under the conditions provided in point (f) of Article 57 paragraph 1 of the General Data Protection Regulation.

C. Information on the processing of personal data

Insofar as we, as controller, alone or jointly with others, determine the purposes and means of the processing of personal data, you will find information below in particular on

  • the personal data or categories of personal data concerned,
  • the purposes for which the personal data are intended to be processed,
  • the legal basis for the processing and, where the processing is based on point (f) of Article 6 paragraph 1 of the General Data Protection Regulation, the legitimate interests pursued by us or by a third party,
  • the recipients or categories of recipients of the personal data, if any,
  • where applicable, the fact that we intend to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the EU Commission, or in the case of transfers referred to in Article 46 or 47 of the General Data Protection Regulation, or the second subparagraph of Article 49 paragraph 1 of the General Data Protection Regulation, reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available,
  • the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period,

Where we obtain your personal data from you as the data subject, you also find below information on whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failure to provide such data.

Where we do not obtain personal data from you as the data subject, you will also find below information on from which source the personal data originate, and if applicable, whether it came from publicly accessible sources.

I.  Planning, organisation and execution of training and preparation of certifications

In the context of the Academy courses, personal data are processed for the purposes of planning, organising and conducting training and preparing for certification.

Below you will find detailed information on this:

​​​​​​​1.  Details about the personal data processed

Categories of personal data processed

Personal data contained in the categories

Sources of the data

Obligation to provide the data

Retention period

Participant master data

Mandatory details: Title, first name, surname, address, billing address, telephone number, email address. 

Optional details: Mobile phone number, company, job title

Participant as the data subject, employer of the participant

Provision of the data is required for the concluding of a contract regarding participation in Academy courses.

If the data are not provided, it is not possible to participate in the Academy courses.

 

We only store data for as long as we need it for the relevant processing goal and/or as long as there are legal retention obligations we must fulfil.

Instructor master data

First name, surname, address, billing address, telephone number, email address, gender, job title, area of expertise

External instructor as the data subject, website of external instructor

Provision of the data is required for the concluding of a contract for engagement as an external instructor.

If the data are not provided, it is not possible to be engaged as an instructor on the Academy courses.

 

We only store data for as long as we need it for the relevant processing goal and/or as long as there are legal retention obligations we must fulfil.

Training course data

Per firm/participant: courses (both attended and registered for), successful completion.

 

Internal systems

 

We only store data for as long as we need it for the relevant processing goal and/or as long as there are legal retention obligations we must fulfil.

Certification data

Data processed about certifications, for example data that identify which certifications a participant has registered for or participated in.

First name, surname, address, date of birth, place of residence/canton for Swiss nationals, nationality for non-Swiss nationals.

SAQ Swiss Association for Quality

Zühlke Academy requires the information needed to conclude the contract.

A possible consequence of the non-provision of data is the inability of Zühlke Academy to issue invoices. 

 

We only store data for as long as we need it for the relevant processing goal and/or as long as there are legal retention obligations we must fulfil.


​​​​​​​​​​​​​​2.  Details about the processing of the personal data

Purpose of the processing of personal data

Categories of personal data processed

Automated decision-making

Legal basis and, if applicable, legitimate interests

Recipient

Planning, organisation and execution of training in order to fulfil the contract with the external participant or his/her employer regarding participation in the Academy course and to fulfil the contract with the instructor regarding engagement as an external instructor on the Academy course.

To administer the training courses, we use a web-based trainngplatform from a specialist training platform provider.

For the preparation of the training courses, we provide instructors with participant lists for the training courses, containing the names of the participants.

Participant master data, instructor master data, training course data

 

No automated decision-making takes place.

 

To the extent that we process a participant's data in order to fulfil the contract with the respective participant regarding participation in the Academy course or process an instructor's data in order to fulfil the contract with the respective instructor regarding engagement as an external instructor, the legal basis is the fulfilment of a contract for which a contracting party is the data subject (Article 6 (1) point b of the General Data Protection Regulation).

To the extent that we process a participant's data in order to fulfil the contract with the employer of the respective participant regarding participation in the Academy course, the legal basis is a balancing of interests (Article 6 (1) point f of the General Data Protection Regulation). Our legitimate interest is the fulfilment of the contract regarding participation in the Academy course.

 

Training platform administrator (Academy employee), Finance and Controlling department (F&C), Business Development department (BD), external instructor, training platform provider (The Namers).

 

Preparation for certification to fulfil the contract with the external participant regarding participation in the Academy course.

To do this, we submit the participant list to the respective certification body so that they can send invitations to certification examinations directly to the participants.

 

Participant master data, certification data

 

No automated decision-making takes place.

 

Fulfilment of a contract in which a contractual party is the data subject (Article 6 (1) point b of the General Data Protection Regulation)

Training platform administrator (employee at Zühlke Academy), certification body

 

At the request of the participant, the Academy can check for which training course the participant has registered or when the participant successfully completed the training course.

Participant master data, certification data, training course data

No automated decision-making takes place.

 

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is to answer the requests of the participants.

Training platform administrator (employee at Zühlke Academy)

For corporate clients, the history is checked to ascertain in which topics the company employees have already been trained.

Participant master data, certification data, training course data

No automated decision-making takes place.

 

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is to provide firms with a tailored offer regarding courses.

Training platform administrator (employee at Zühlke Academy)


​​​​​​​​​​​​​​2.  Details on the recipients of the personal data and details on the transfer of personal data to a third country and/or international organisation

Recipient

Role of the recipient

Location of the recipient

Adequacy decision or appropriate or suitable guarantees regarding transfers to third countries and/or to international organisations

Training platform administrator (employee at Zühlke Academy)

Division of the controller

Switzerland

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

Business Development department (BD)

Division of the controller

Switzerland

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

External instructor

Controller

Switzerland

 

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

Certification provider

Scrum.Org

131 Middlesex Turnpike

Burlington, MA, 01803

United States of America

 

Scaled Agile

5480 Valmont Rd, Suite 100

Boulder, CO, 80301

United States of America

 

SAQ Swiss Association for Quality

Stauffacherstrasse 65/42

3014 Bern BE

Switzerland

Controller

USA

Switzerland

 

 

 

 

 

 

Adequacy decision: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=uriserv%3AOJ.L_.2016.207.01.0001.01.DEU

 

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

Training platform provider

The Namers

Rotbuchstrasse 11

8006 Zürich

Data processor

Switzerland

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

Zühlke Engineering AG, Switzerland

 

 

Switzerland

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

 

  1. II.  Academy email newsletter

Zühlke offers participants on the Academy courses the opportunity to register for an email newsletter. When you register to receive the email newsletter, certain items of information are collected, such as your email address, for example. We process this information in order to be able to provide the email newsletters.

More detailed information about this is available below:

​​​​​​​1. Details on the personal data processed

 

Purposes of the processing of the personal data

Categories of personal data processed

Automated decision-making

Legal basis and, where applicable, legitimate interests

Recipients

In order for the form for subscription to and unsubscription from our newsletter to be made available on the website, HTTP data is temporarily processed on our web server.

 

 

HTTP-Data.

 

No automated decision-making takes place.

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is the provision of the website content called up by the user.

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have subscribed, the hosting provider.

Double opt-in process for confirmation of the request to receive emails (subscription).

For this purpose, we send an email message to the email address supplied, requesting confirmation. A subscription only comes into effect when the subscriber confirms the email address by clicking on the confirmation link contained in the email.

 

Subscription data, registration and deregistration data.

No automated decision-making takes place.

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is the legally secure documentation of your consent to receive the newsletter.

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have registered, email campaign management provider.

Sending of emails containing event invitations, newsletters, information about Zühlke and other offers from Zühlke, such as training courses, for example.

We use an external provider's email campaign management system for the administration and sending of emails.

We use the optional information supplied upon registration to customise the design of the newsletter and to select information that is relevant to the specific recipient.

 

Subscription data, registration and deregistration data.

No automated decision-making takes place.

Consent (article 6 (1) section a of the General Data Protection Regulation).

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have registered, email campaign management provider.

Storing and processing for evidentiary purposes for the establishment, exercise or defence of possible legal claims.

Subscription data, registration and deregistration data.

No automated decision-making takes place.

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is the establishment, exercise or defence of legal claims.

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have registered, email campaign management provider

​​​​​​​​​​​​​​2. Details on the processing of the personal data

Purposes of the processing of the personal data

Categories of personal data processed

Automated decision-making

Legal basis and, where applicable, legitimate interests

Recipients

In order for the form for subscription to and unsubscription from our newsletter to be made available on the website, HTTP data is temporarily processed on our web server.

 

 

HTTP-Data.

 

No automated decision-making takes place.

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is the provision of the website content called up by the user.

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have subscribed, the hosting provider.

Double opt-in process for confirmation of the request to receive emails (subscription).

For this purpose, we send an email message to the email address supplied, requesting confirmation. A subscription only comes into effect when the subscriber confirms the email address by clicking on the confirmation link contained in the email.

 

Subscription data, registration and deregistration data.

No automated decision-making takes place.

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is the legally secure documentation of your consent to receive the newsletter.

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have registered, email campaign management provider.

Sending of emails containing event invitations, newsletters, information about Zühlke and other offers from Zühlke, such as training courses, for example.

We use an external provider's email campaign management system for the administration and sending of emails.

We use the optional information supplied upon registration to customise the design of the newsletter and to select information that is relevant to the specific recipient.

 

Subscription data, registration and deregistration data.

No automated decision-making takes place.

Consent (article 6 (1) section a of the General Data Protection Regulation).

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have registered, email campaign management provider.

Storing and processing for evidentiary purposes for the establishment, exercise or defence of possible legal claims.

Subscription data, registration and deregistration data.

No automated decision-making takes place.

Balancing of interests (article 6 (1) section f of the General Data Protection Regulation). Our legitimate interest is the establishment, exercise or defence of legal claims.

Marketing Communications Department (MarCom) of the relevant Zühlke company with which you have registered, email campaign management provider


​​​​​​​​​​​​​​3.  Details on the recipients of personal data and details on the transfer of personal data to a third country and/or international organization

Recipient

Recipient’s role

Recipient’s location

Adequacy decision or appropriate or suitable safeguards for transfers to third countries and/or international organisations

Academy Department of the relevant country

Division of the data controller

Switzerland, Asutria

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

Marketing Communications Department (MarCom) of the relevant country

Division of the data controller

Zühlke Engineering AG (ZCH): Switzerland

 Zühlke Engineering GmbH (ZAT): Austria

 

Adequacy decision for Zühlke Engineering AG Switzerland: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

 

Hosting provider

Nine Internet Solutions AG
Albisriederstrasse 243a
8047 Zürich
Switzerland

Data processor

Switzerland

Adequacy decision for Zühlke Engineering AG Switzerland:http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

Email campaign management provider

Episerver Germany
Wallstraße 16
10179 Berlin

Germany

Data processor

Germany

 

Certification provider

Scrum.Org

131 Middlesex Turnpike

Burlington, MA, 01803

United States of America

 

Scaled Agile

5480 Valmont Rd, Suite 100

Boulder, CO, 80301

United States of America

 

SAQ Swiss Association for Quality

Stauffacherstrasse 65/42

3014 Bern BE

Switzerland

Data controller

USA

Switzerland

 

Adequacy decision: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=uriserv%3AOJ.L_.2016.207.01.0001.01.DEU

Adequacy Decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

 

Schulungsplattform-Anbieter

The Namers

Rotbuchstrasse 11

8006 Zürich

Switzerland

Data processor

Switzerland

Adequacy decision: http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32000D0518

 

D.  Effective date of and changes to this Data Protection Information

 

The effective date of this Data Protection Information is May, 20th 2018.

​​​​​​​It may be necessary to modify this Data Protection Information due to technical developments and/or amendment of statutory or official requirements.

An up-to-date version of this Data Protection Information can be retrieved at any time at https://www.zuehlke.com/at/en/about-us/academy/privacy-policy/