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Privacy Policy of InterNations GmbH (InterNations)

for the use of the services under the top level domain www.internations.org and the InterNations mobile applications

Version: 07 December 2018 Save | Print

Part A: Privacy Principles

Welcome to InterNations! The protection of your privacy and your personal data is taken very seriously and of utmost concern for InterNations.

InterNations is a community of trust. InterNations ensures highest standards for the protection of your personal data and your privacy. This Privacy Policy is designed to help you better understand how InterNations collects and deals with your personal data and information.

InterNations works hard to earn and keep your trust. Therefore, InterNations uses personal data solely to provide you with the InterNations Services. InterNations will never rent, sell, or otherwise provide personal data to any third party for advertising or for marketing purposes without your consent.

  1. Responsible body

    As a visitor to our website, you expect a high level of quality not only from our platform, but also from the processing of your personal data. We are responsible for the handling of your data, which we process according to your wishes and the requirements of the German and EU data protection laws. Personal data is data that identifies you or makes you identifiable. We only process personal data if this is permitted by law or if you have given your prior consent.

    The responsible body for the collection and processing of personal data is:

    InterNations GmbH
    Schwanthalerstr. 39
    80336 Munich
    Germany
    Tel: +49 (0)89 4613324-0
    Email: info@internations.org

    If you have any questions about data protection or data security, please contact our data protection officer

    Herr Bernd Fuhlert
    @-yet GmbH
    Der Datenschutzbeauftragte der InterNations GmbH
    Schloss Eicherhof
    42799 Leichlingen
    Germany
    Email: support@internations.org

    Our service providers include, for example, data centers, analysis service providers, and payment service providers. Our service providers are prohibited from processing your data for other purposes or for themselves. It is important to us that you can find out at any time from the following information which personal data is collected during your visit to our website and when ordering in our shop and how we process it afterwards.

  2. Your rights in data protection and right to cancel

    You have the following rights regarding the processing of personal data:

    1. Right of access by the data subject to the personal data concerned
    2. Right to rectification or erasure or restriction of processing
    3. If the processing of your personal data is based on a weighing of interests (Art. 6 (1) (f) GDPR) or if the processing is necessary for the performance of a task which is in the public interest or is carried out in the exercise of official authority vested in the controller (Art. 6 (1) (e) GDPR), the right to object to the processing. We will inform you about this in detail in the following sections.
    4. Right to data transfer
    5. If the processing of your personal data is based on your consent (Art. 6 (1) (a) or Art. 9 (2) (a) GDPR), you have the right to withdraw your consent at any time. We will inform you about this in detail in the following sections.
    6. Right of appeal to a supervisory authority

    You have the right to object to the processing of your data at any time for reasons arising from your particular situation if the legal requirements are met. If you object to the processing of your data for advertising purposes or wish to revoke your consent, a short message to our data protection officer by email to support@internations.org or by post to InterNations GmbH, Schwanthalerstr. 39, 80336 Munich, Germany is sufficient at any time. Your data will then no longer be processed for the advertising purposes covered by the advertising objection or the revocation of consent. This does not affect the legality of the processing carried out until the objection or revocation. After your objection to the processing of your personal data for advertising purposes or the revocation of your consent, we are obliged under data protection law in accordance with the requirements of the German data protection supervisory authorities to include the necessary data (name, address, e-mail address) in our internal advertising blacklist and - only for this purpose - to permanently store (block) and use for comparison with our future advertising files. (Art. 21 (3), Art.17 (3) (b), Art.6 (1) (c) DSGVO). In this way, compliance with your advertising objection or the revocation of your consent can be permanently ensured. If you have any questions about the processing of your personal data by us, we will of course be happy to provide you with information about the data concerning you at any time. Furthermore, you have a right to correction, deletion, restriction of processing, objection, and the right to data transfer if the legal requirements are met. In all these cases, please contact our data protection officer (see contact data under item 1) at the communication addresses listed there. Finally, you have the right to complain to a competent data protection supervisory authority.

  3. Processing of personal data on our website

    1. Visiting our website

      InterNations GmbH - as it is usual and necessary for internet pages to be used - processes so-called server log files when you visit our internet page. When our website is accessed, our web server records the domain name or the IP address of your computer, the file name, and the URL which was requested, as well as the http response code and, if applicable, the URL referring to our website (legal basis: Art. 6 (1) (b) GDPR). This procedure is technically necessary and customary to enable the use of our website. Here we are supported by our technical service providers, which we use as contract processors. The above-mentioned data is logged and used for the purpose of defense against illegal use or attempted attacks on our web server (Art. 6 (1) (f) GDPR). The data will be deleted after 60 days.

    2. Registration on the platform

      If you register for our platform on our website, we process the data provided for this purpose in order to provide you with the platform (legal basis: Art. 6 (1) (b) GDPR). The mandatory information requested during registration is a prerequisite for fulfilling the service. We require your date of birth as proof of age, as our offer is only aimed at persons who have reached the age of 18. We need your email address to send you a confirmation and notifications. Within the scope of registration and use of our service, the processing is necessary for the fulfilment of the contractual service such as the provision of the platform and payment processing. The contract with you is thus the legal basis for this processing (Art. 6 (1) (b) GDPR). We will also process your data to the extent required by law to fulfill our archiving and storage obligations in accordance with German commercial and tax law (Art. 6 (1) (c) GDPR). The provision of personal data and registration data is necessary for the conclusion of the contract. In addition, we use your data for direct advertising - i.e. to send you information about our services and campaigns (in accordance with Art. 6 (1) (f) GDPR) in order to win you as a customer (information in accordance with Art. 13 (1) (d) GDPR). You can object to the use of your data for advertising purposes at any time under the above contact details. We will process your data within the scope of registration as long as you do not request deletion, unless there are contractual or legal reasons for not doing so.

    3. Registration on the platform premium

      If you order a service from us, it will be processed to fulfill the contractual service such as delivery and payment processing. The sales contract with you is the legal basis for this processing (Art. 6 (1) (b) GDPR). We will also process your data to the extent required by law to fulfill our archiving and storage obligations under German commercial and tax law (Art. 6 (1) (c) GDPR). In addition, we use your data for direct advertising - i.e. to send you information about our products and campaigns (in accordance with Art. 6 (1) (f) GDPR) in order to win you as a customer (information in accordance with Art. 13 (1) (d) GDPR). You can object to the use of your data for advertising purposes at any time under the above-mentioned contact data. Further recipients of these data within the scope of the handling of the contract about the order are payment service providers (only payment data). The duration of the processing depends on the purpose of the fulfillment of the contract as well as the associated further legal requirements for storage and proof. We use the data for direct advertising as long as you have not objected.

    4. User content

      After successful registration with InterNations, you may provide additional information about yourself (e.g. international experience, professional background, interests). Providing additional information beyond what is required at registration is entirely optional and on a voluntarily basis but enables you to better use our services. Additionally, you can upload, publish, send, or display comments, photos, profiles, messages, notes, text, information, music, video, advertisements, listings, and other content (User Content) on or through InterNations, or transmit to or share with other users accessing the InterNations websites. You may also form relationships with other users, perform searches and queries, and form groups. InterNations collects all the aforementioned information so that InterNations can provide you with the services and offer personalized features. In most cases, InterNations retains the information so that, for instance, you can return to view prior messages you have sent.

      If you visit a profile of another user of InterNations, this user may see that you have visited his/her profile. This feature is an essential part of contact management on InterNations and as such an essential part of the InterNations services.

      Any information and user content (except personal messages to other users) you have submitted to InterNations or to others via our platform may be accessed by third parties when they visit the InterNations websites. Such information and content may also be found and made accessible by search engines.

      If you choose to invite other people to InterNations to join your network, the names and email addresses of the invitees need to be entered. The names and email addresses of people that are invited will be used by InterNations only to send your invitation email (including an optional personal message) and corresponding reminders. InterNations stores this information to send the invitation email, to register a contact connection if your invitation is accepted, and to track the success of InterNations’ referral program.

    5. Google Analytics

      In the context of our platform we use the functions of the web analysis service Google Analytics. Provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called "cookies". These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. The Google Analytics cookie (legal basis Art. 6 (1) (f) GDPR) is stored because of our legitimate interest in analyzing user behavior in order to optimize our website and advertising. We are supported in this by Google as a contract processor. Google will use this information for the purpose of evaluating the user's use of the website, compiling reports on website activity and providing other services to website operators relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google.

      IP Anonymization: The IP anonymization function is activated on our website. Your IP address will be shortened by Google within the European Union or in a contracting state of the Agreement on the European Economic Area before transmission to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. The legal basis for a transfer of personal data is the so-called EU-US Privacy Shield.

      Browser Plugin: You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. In addition, you can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and prevent Google from processing this data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

      Objection to data collection: You can prevent Google Analytics from collecting your data by clicking on the following link. Disable Google Analytics. An opt-out cookie is set to prevent the collection of your information on future visits to this website. For more information on how Google Analytics uses user data, please refer to Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

      Data processing agreement: We have concluded an agreement with Google for data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

      Demographic features of Google Analytics: This website uses the "demographic features" function of Google Analytics. This allows reports to be generated that contain information on the age, gender, and interests of website visitors. This data comes from interest-related advertising by Google and from visitor data from third parties. This information cannot be associated with any specific individual. You can deactivate this function at any time via the ad settings in your Google Account or generally prohibit Google Analytics from collecting your data as described under "Objection to data collection".

    6. Hotjar

      We use Hotjar, developed by Hotjar Limited, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.). This enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular a device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For more information please review the Hotjar privacy policy available under: https://www.hotjar.com/legal/policies/privacy

      You can opt out to the creation of a user profile, Hotjar’s storing of data about your usage of our site, and Hotjar’s use of tracking cookies on other websites by following this opt-out link: https://www.hotjar.com/legal/compliance/opt-out

    7. New Relic

      We use New Relic, developed by New Relic, 101 Second Street, 15th Floor, San Francisco, CA 94105, USA, to monitor the performance of our servers as well as the client-side performance of our website. The tool collects potentially personally identifying information such as internet protocol addresses and database queries. Neither New Relic nor we will use this information to identify individual users. New Relic is fully compliant with European data protection laws and certified under the EU-US Privacy Shield. For more information, please review the New Relic privacy policy available under: https://newrelic.com/privacy

    8. Survey Monkey

      InterNations uses SurveyMonkey, developed by SurveyMonkey, One Curiosity Way, San Mateo, CA 94403, USA, to conduct online surveys. Usage data as well as the information that you enter in our surveys will be stored and processed on servers in the US. SurveyMonkey is fully compliant with European data protection laws and certified under the EU-US Privacy Shield. For more information please review the SurveyMonkey privacy policy under: https://www.surveymonkey.com/mp/legal/privacy-policy/.

    9. TrackJS

      We use TrackJS, developed by TrackJS LLC, to keep track of JavaScript errors on our website. The tool collects potentially personally identifying information such as internet protocol addresses. Neither TrackJS nor we will use this information to identify individual users. The service is provided in compliance with EU data protection regulations using a data processing agreement. For more information, please review the TrackJS privacy policy available under https://trackjs.com/privacy

    10. Social Media

      There are no social plugins on our website, especially not the "Like" button of the social network facebook.com. We only link to our own social media profiles. If you are logged into your social media account and follow the respective link, the social network will be able to assign your visit to our website to your user account there. If you do not want your social networks to be able to assign your visit to our website to your user accounts there, you must log out of your social media accounts before clicking any of these links.

    11. Contact/Inquries

      If you have any questions or requests, please do not hesitate to contact us. We process your data to answer your service requests (Art. 6 (1) (b, f) GDPR). The communication of address and telecommunication data marked as mandatory data is necessary in order to process and answer your request. The voluntary provision of further data makes it easier for us to process your enquiry. We store the information from your inquiry after answering the inquiry generally for six years, if it concerns commercial or business letters (§ 257 Abs.4 HGB, Art. 6 (1) (c) GDPR).

    12. Email Advertising

      With your explicit consent, which can be revoked at any time, we will inform you by email about our products and campaigns such as updates and events of our platform and/or about our various product newsletters (§ 7 Abs.2 Nr.3 UWG). We process your obligatory information when granting your consent in order to send you the newsletter(s) you have chosen and to address you personally (Art. 6 (1) (f) GDPR). In order to receive certain newsletters, you must first register (see explanation under Registration). When obtaining your consent, we use the so-called double opt-in procedure online to prevent our email messages from being sent to email addresses of persons who have not requested or do not want them. Your IP address is also recorded and stored for documentation purposes in accordance with the specifications of the data protection supervisory authorities. (Art. 7 (1), Art. 6 (1) (c) GDPR). We store your data collected for advertising purposes as long as the advertising purpose exists or until we receive a revocation of your consent or your objection to the processing of your data for advertising purposes.

    13. Change of Purpose

      If we should change the purposes of the processing in the course of the time, we will inform you by an update of these references to the data protection in advance.

    14. Extended retention periods

      The specified storage periods may be extended accordingly if a longer statutory or contractual storage period exists in individual cases, in particular if the data are processed for different purposes.

  4. What are mandatory fields?

    If certain data fields are designated as mandatory fields and/or marked with an asterisk ( * ), the provision of this data is either required by law or contract, or we need this data for the conclusion of the contract, the desired service, or the stated purpose. Of course, you also have the right to specify the data in the mandatory fields at your discretion. Failure to provide this information may result in the contract not being fulfilled by us or the desired service not being provided, or the stated purpose not being achieved.

  5. Information on cookies and newsletters

    1. Cookies

      The InterNations GmbH website uses web analysis technologies to collect and use data for optimization purposes. These are described and explained below separately and in more detail. In the interest of clarity, we would like to explain the subject of cookies to you here. Cookies are small text files that are stored on your computer. These are used to enable the recognition of your internet browser. These data are used to create user profiles under a pseudonym. Unless you have given your separate consent, this data will not be used to identify you personally and will not be merged with personal data about the bearer of the pseudonym. IP addresses are used in this procedure only in anonymous form. We use this data exclusively to optimize our services and to tailor them to the needs of our customers. You can object to the creation of pseudonymous user profiles by setting an opt-out cookie. In addition, we use cookies to make the use of our online platform customer friendly. For this purpose, we use information about the date and duration of a visit to our website as well as the pages viewed by the visitor. Most browsers are set to automatically accept cookies. You can set your web browser so that it notifies you when cookies are set or generally rejects or restricts the setting of cookies. If you deactivate or restrict cookies using your browser, you will no longer be able to use various functions on our website. You can delete cookies stored in your web browser at any time, even automatically.

      The following links will inform you about this possibility for the most frequently used browsers:

      • Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
      • Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
      • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

      If you have not made or do not make any other settings, cookies, which enable and are intended to ensure the necessary technical functions, will remain on your device until you close the browser, other cookies may remain on your device for longer.

    2. Newsletter as registered user

      If you subscribe to our newsletter, you agree that we will regularly inform you about current offers and competitions of InterNations GmbH and interesting facts about living abroad by email and invite you to surveys. You can revoke your consent at any time, e.g. in your account settings, via the email address support@internations.org, or by clicking on the unsubscribe link in any newsletter (to unsubscribe from that newsletter). We will use your data until you revoke your consent.

  6. Service provider for the processing of payments

    The payment and bank information that is stored or entered within the framework of an order is processed for the purpose of payment processing, so we can provide our contractual service to you (legal basis: Art. 6 (1) (b) GDPR). Furthermore, we use companies as contract processors in order to be able to offer our customers payment methods customary in the market. These include Amex, Visa, PayPal (Art. 6 (1) (f) GDPR). The data will be kept until the statute of limitations of the mutual claims and the necessary data will be kept within the scope of fulfilling the commercial and tax retention periods (Art. 6 (1) (c) GDPR).

  7. Breach of Obligations

    In the event InterNations has good reason to believe that you have breached your obligations under Section 5 of the GTC, InterNations will review your personal data, communication, and networking to the extent as required to verify such a breach.

  8. Links

    InterNations may contain links to other websites. InterNations is not responsible for the privacy practices of other websites. InterNations encourages you to be aware when you leave the InterNations websites to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by InterNations.

  9. Data security

    We take technical and organizational security precautions to protect your personal data against accidental or intentional manipulation, loss, destruction, or against access by unauthorized persons and to guarantee the protection of your rights and compliance with the applicable data protection regulations of the EU and the Federal Republic of Germany. The measures taken should guarantee the confidentiality and integrity of your data as well as the availability and resilience of the systems and services when processing your data in the long term. They should also quickly restore data availability and access in the event of a physical or technical incident. Our security measures also include encryption of your data. All information that you enter online is technically encrypted and only then transmitted. This means that this information cannot be viewed by unauthorized third parties at any time. Our data processing and security measures are continuously improved in line with technological developments. The employees of InterNations GmbH are or will be obliged in writing to maintain confidentiality and to comply with the data protection requirements of the GDPR.

  10. Changes

    This Privacy Policy must be adapted from time to time to the actual circumstances and the legal situation. Please check the Privacy Policy before using our platform to keep up to date with any changes or updates.