**Privacy Policy** This document explains how we process your personal data (data) within the Klett ESD Network (Klett ESD) **I.  Who is responsible for processing your data, and whom can you contact in this regard?** Both Ernst Klett AG, Rotebühlstraße 77, 70178 Stuttgart, e-mail [info@klett-gruppe.de](mailto:info@klett-gruppe.de) as well as the Klett subsidiary where you are employed. If you have any questions regarding data protection, you can contact both the data protection officer of Ernst Klett AG, Rotebühlstrasse 77, 70178 Stuttgart, e-mail [b.spickenheier@klett-gruppe.de](mailto:b.spickenheier@klett-gruppe.de) as well as the data protection officer of the Klett subsidiary at which you are employed. Ernst Klett AG is responsible for the provision of consistent advice and information as well as coordination of the Klett ESD Network for the purpose of collaboration within the Klett Group. The legal basis for this is Article 6 (1) (f) GDPR. In an agreement on joint data control responsibilities pursuant to Article 26 of the GDPR, it was determined with the participating companies who fulfils which obligations under data protection law. We will provide you with the essential content of this agreement upon request. **II.  Processing of personal data** The use of your data is governed by the applicable legal provisions, in particular the General Data Protection Regulation (hereinafter: GDPR), the Telecommunications Telemedia Data Protection Act (hereinafter: TTDPA) and the Federal Data Protection Act (hereinafter: BDSG). **1. Registration with the Klett ESD Network (Klett ESD)** To register, you must provide your name and surname, your business e-mail address, which will serve as your user ID, and a password (access data) so that only you can log in. After registration, you will receive a confirmation e-mail from us with a link to confirm your e-mail address. We are permitted to process the data you provide upon registration in accordance with Article 6 (1) b) GDPR if there is a contractual obligation to provide your data. We are also permitted to process the data in accordance with Article 6 (1) (f) GDPR as we have a legitimate interest in exchanging data within the Klett Group. We are also permitted to process data that you voluntarily provide to us when placing an order or registering in accordance with Article 6 (1) (a) and, if applicable, also (f) GDPR, provided that you have consented to this processing by selecting ‘Create user account’. Such data includes your telephone number, your company details, your position, your location and the ‘About me’ section. This voluntary information is processed in order to contact you faster and for internal statistical purposes. The legal basis for this is Article 6 (1) (a) and, if applicable, (f) GDPR. **2. Visiting [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de)** **a. Server log files** When you visit [https://esd-network.klett-gruppe.de,](https://esd-network.klett-gruppe.de,) we save, for a maximum of 1 week, your IP address and the date and time of your visit; information on your device’s operating system and the browser you use, including your language settings; the address of the website from which you accessed [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) (also known as a ‘referrer URL’); the names of the files you access; and the amount of data transferred in the process. We receive this information from your Internet service provider. For technical reasons, much of the data involved has to be saved in order to display [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) on your computer or smartphone and to safeguard system security. It is also analysed in anonymised form for statistical purposes and to improve the quality of [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) (see also section II, 2 c below). None of this data is linked to the personal data of any specific natural person. This data is processed on the basis of Article 6 (1) (f) of the GDPR. We have a legitimate interest in ensuring the proper presentation of [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) on your screen, our ability to swiftly address the causes of hacking attempts and other disruptions, and the means by which we analyse this anonymised data for statistical purposes. While the provision of said data is not stipulated by law or any contract, not processing the bulk of the data in question would make using [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) impossible for related technical reasons. **b. Cookies** When you visit [https://esd-network.klett-gruppe.de,](https://esd-network.klett-gruppe.de,) session cookies are used. Cookies are small files that contain identification numbers assigned by our company. When you visit [https://esd-network.klett-gruppe.de,](https://esd-network.klett-gruppe.de,) cookies are stored on your computer or smartphone. If you access [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) again during the same browser session, the identification number assigned makes it possible to recognise your device. Session cookies enable you to remain logged in to [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) even if you visit various other sites in the meantime. Session cookies are deleted when you close your browser. We are permitted to set session cookies in accordance with Article 6 (1) (f) of the GDPR and § 25 Abs. 2 TTDPA. We have an interest in making the Klett ESD Network (Klett ESD) a user-friendly experience, which includes enabling you to remain logged in to the Klett ESD Network (Klett ESD) website even if you access other websites in the meantime. You can also visit [https://esd-network.klett-gruppe.de](https://esd-network.klett-gruppe.de) without storing our cookies. There is no obligation to use cookies. While most browsers accept cookies automatically, you can configure yours to deny them or notify you before they are used. These settings must be configured separately for every browser and device you use. Information on how to deactivate cookies can typically be found through your browser’s help function. **d. Data recipients** We transmit the data described above to the following processors, which process your data based solely on our directives and not for their own purposes: **Support and maintenance of [https://esd-network.klett-gruppe.de:](https://esd-network.klett-gruppe.de:)** HumHub GmbH & Co. KG Tassiloplatz 28 81541 Munich, Germany **Data centre:** Hetzner Online GmbH Industriestrasse 25 91710 Gunzenhausen, Germany **System administration:** Ernst Klett AG Corporate Communications Department (UK) Rotebühlstr. 77 70178 Stuttgart, Germany **3. Use of the Klett ESD Network (Klett ESD)** **a. What are the purposes and legal bases for processing your data in the Klett ESD Network (Klett ESD)?** We process your data for the following purposes: (1) Maintaining a networking platform for ESD ambassadors within the Klett Group (2) Identification with the Klett Group (3) Advising subsidiaries on the subject of ESD (3) Sharing information with ESD ambassadors (4) Providing information material (e.g. publications) (5) Providing ambassador contacts (6) Sending invitations to events (e.g. webinars on ESD) (7) Posting surveys (8) Providing a space for joint project work by ESD ambassadors We process your data and the data you have posted or published on the Klett ESD Network based on your granted consent pursuant to Art. 6 para. 1 a) GDPR. We are also processing on this base the data in accordance with Article 6 (1) (f) GDPR as there is a legitimate interest in exchanging information within the Klett Group. We may also process special categories of data (information about your religion, political views, union affiliation or health, for example) that you have voluntarily posted or uploaded to the Klett ESD Network (esd-network). We ask you not to publish such data on the Klett ESD Network (esd-network). In addition, we process your data in accordance with Art. 6 (1) f) GDPR, as there is an interest in exchanging information within the Klett Group. We may process your data for the purpose of investigating criminal offences on the basis of Article 88 GDPR in conjunction with Section 26 (1) sentence 2 BDSG. **b.         What data is processed?** We process the following data pertaining to your person, which you post to the Klett ESD Network (Klett ESD): ·         Name, first name, salutation, title ·         E-mail address ·         Company for which you work, role and position ·         Telephone number ·         Other data that you publish on the Klett ESD Network (Klett ESD) or post to the Klett ESD Network (Klett ESD) **c.         How long will your data be stored?** As long as you remain registered with the Klett ESD Network (Klett ESD), will store the data you provide to the Klett ESD Network (Klett ESD) at least until you withdraw your consent. We may also store data required for the assertion or defence of legal claims until the expiry of the statutory limitation periods, up to a maximum of 30 years, provided that a legal dispute is already pending at the time consent is withdrawn or the employment relationship terminated. **d. Will your data be passed on to third parties?** The Klett ESD Network (Klett ESD) is used for the exchange of information by selected ambassadors of the Klett Education Group. Therefore, all data that you publish on the Klett ESD Network (Klett ESD) can be viewed by the selected ambassadors of the companies listed below and will be passed on to other employees within the subsidiary. The recipients of your data are therefore the companies listed under the following link and their employees: [https://esd-network.klett-gruppe.de/file/file/download?guid=0b3f7887-12ca-4116-9b9d-ebf54bc1fd00&hash_sha1=f7c6f2d2](https://esd-network.klett-gruppe.de/file/file/download?guid=0b3f7887-12ca-4116-9b9d-ebf54bc1fd00&hash_sha1=f7c6f2d2) We may also share this data with the following recipients: · Police for the purpose of investigating offences · Courts involved in asserting or defending our rights We also transfer this data to our processors mentioned above under II. 2. c. **III. What rights do you have as far as your information is concerned?** Pursuant to Article 15 of the GDPR, you have the right to request information about whether the Ernst Klett AG process your data (and if so, which data). You can also ask that your data be corrected (and completed, if applicable) in accordance with Article 16 of the GDPR. The GDPR further grants you the right to have your data deleted (Article 17) or restricted (Article 18). In line with Article 21 of the GDPR, you are entitled to receive any of your data that has been transmitted to us based on your consent or a corresponding contract, provided that the processing in question is automated. If you prefer it and doing so is technically feasible, we will transmit this data to a third party. **In cases in which we process data to preserve our interests on the sole basis of Article 6 (1) (f) of the GDPR, you have the right to object to the processing of your data for reasons pertaining to your particular situation. If you raise such an objection, we will no longer process the data in question unless we can prove that there is compelling justification for the continuation of said processing and it takes precedence over your interests, rights, and freedoms; or the processing is necessary to enforce valid legal claims.** If you have consented to the processing of your data, you have the right to withdraw your consent at any time. You will not face any negative consequences by doing so. Withdrawing your consent will not affect the legality of the processing performed up to that point. You can withdraw your consent by sending an e-mail to [info@klett-gruppe.de](mailto:info@klett-gruppe.de). Once you withdraw your consent, your data will no longer be processed unless we are legally entitled or obligated to do so. Finally, you have the right to lodge complaints regarding the applicable data protection laws, in particular with the Baden-Württemberg state representative for data protection and freedom of information (Landesbeauftragter für Datenschutz und Informationsfreiheit, Lautenschlagerstr. 20, 70173 Stuttgart, Germany). Last updated: 15.02.2022