Last updated: April 2022
Privacy Policy
With this privacy policy we inform you which personal data we process in connection with our activities and operations, including our nu.education website. In particular, we provide information on why, how and where we process personal data. We also provide information about the rights of persons whose data we process.
For individual or additional activities and operations, further privacy policies and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.
We are subject to Swiss data protection law as well as any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law guarantees adequate data protection.
1 Contact addresses
Responsibility for the processing of personal data:
NU Technology AG
Feldeggstrasse 24
8008 Zurich
r.l@nu.education
We would like to point out if there are other persons responsible for the processing of personal data in individual cases.
1.1. Data protection officer
We have the following data protection officer as a point of contact for data subjects and as a point of contact for supervisory authorities in the event of data protection enquiries:
Ramon Lisibach
NU Technology AG
Feldeggstrasse 24
8008 Zurich
r.l@nu.education
1.2 Data protection representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 GDPR. The data protection representative serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries in connection with the General Data Protection Regulation (GDPR):
VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg
Hamburg, Germany
info@datenschutzpartner.eu
2. Terms and legal bases
2.1 Definitions
Personal data is any information relating to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, erasure, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, erasure, storage, modification, destruction and use of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (OFADP).If and insofar as the General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the fulfilment of a contract with the data subject and for the implementation of pre-contractual measures.
Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
3. Type, scope and purpose
We process the personal data required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.
We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.
In principle, we only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons, for example to fulfil a contract with the data subject and for corresponding pre-contractual measures, to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject voluntarily and personally provides to us when contacting us - for example by post, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such data in an address book, in a customer relationship management system (CRM system) or with comparable tools, for example. If you transmit data about other persons to us, you are obliged to guarantee data protection for such persons and to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.
4. Personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.
We may export personal data to all countries and territories on earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in the opinion of the Federal Data Protection and Information Commissioner (FDPIC) or in accordance with a decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - in accordance with a decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of guarantees on request.
5. Rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information and the right to rectification, erasure or blocking of the processed personal data.
Data subjects whose personal data we process can - if and insofar as the General Data Protection Regulation (GDPR) is applicable - obtain confirmation free of charge as to whether we process their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data rectified, erased (‘right to be forgotten’), blocked or completed.
Data subjects whose personal data we process can - if and insofar as the GDPR is applicable - withdraw their consent at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects whose personal data we process have the right to lodge a complaint with a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
6. Data security
We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. Unfortunately, however, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication - like all digital communication - is subject to mass surveillance without cause or suspicion and other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities.
7. Use of the website
7.1 Cookies
We may use cookies. Cookies - both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) - are data that are stored in your browser. Such stored data need not be limited to traditional cookies in text form. Cookies cannot execute programmes or transmit malware such as Trojans and viruses.
Cookies can be stored temporarily in your browser during your visit as ‘session cookies’ or for a certain period of time as so-called permanent cookies. ‘Session cookies’ are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognise your browser the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
You can completely or partially deactivate and delete cookies in your browser settings at any time. Without cookies, our website may no longer be fully available. We actively request your express consent for the use of cookies, if and to the extent necessary.
7.2 Server log files
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer or referrers).
We store such information, which may also constitute personal data, in server log files. The information is required to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.
7.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.
8. Notifications and messages
We send notifications and messages by e-mail and via other communication channels such as instant messaging or SMS.
8.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for measuring success and reach in order to be able to send notifications and messages in an effective, user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
8.2 Consent and objection
You must always expressly consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. Wherever possible, we use the ‘double opt-in’ procedure to obtain consent, i.e. you will receive an e-mail with a web link that you must click on to confirm, so that no misuse by unauthorised third parties can occur. We may log such consents, including the Internet Protocol (IP) address, date and time, for reasons of proof and security.
In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
We use in particular:
Mailchimp: Communication platform; Provider: The Rocket Science Group LLC d/b/a Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); Data protection information: Privacy Policy (Intuit) including ‘Country and Region-Specific Terms’, Cookie Policy, ‘Privacy Rights Requests’, ‘Mailchimp and European Data Transfers’, ‘Security’.
9. Social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The General Terms and Conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
Our social media channels: LinkedIn - Instagram
10. Services from third parties
We use third-party services in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such services may also be used to embed content in our website. Such services require your Internet Protocol (IP) address, as otherwise the corresponding content cannot be transmitted.
For their own security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This may involve, for example, performance or usage data.
We use in particular:
Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: ‘Privacy and security principles’, Privacy Policy, ‘Google is committed to complying with applicable data protection laws’, ‘Privacy Policy for Google products’, ‘How we use data from websites or apps on or in which our services are used’ (information from Google), ‘Types of cookies and other technologies used by Google’, ‘Personalised advertising’ (activation / deactivation / settings).
10.1 Digital infrastructure
We use third-party services in order to be able to utilise the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from specialised providers.
In particular, we use:
Hostpoint: Hosting; Provider: Hostpoint AG (Switzerland); Data protection information: Privacy policy, ‘Frequently asked questions about the GDPR’.
hosttech: Hosting; Providers: hosttech GmbH (Germany) / hosttech GmbH (Austria) / hosttech GmbH (Switzerland); Data protection information: Privacy policy (Germany), Privacy policy (Austria), Privacy policy (Switzerland), ‘Infrastructure’.
10.2 Contact options
We use third-party services in order to communicate better with you and other persons such as customers.
We use in particular:
Jira Service Management (Jira Service Desk): Customer Service; Provider: Atlassian Pty Ltd (Australia) / Atlassian Inc (USA); Privacy Policy: Privacy Policy.
Microsoft Dynamics 365: Customer Relationship Management (CRM); Service provider: Microsoft Corporation (USA); Information on data protection: Privacy Policy, ‘Data protection and personal data for Microsoft Dynamics 365’, ‘Data protection and GDPR’.
10.3 Audio and video conferencing
We use audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or online lessons and webinars. In addition to this privacy policy, any terms and conditions of the services used, such as terms of use or privacy policies, also apply.
Depending on the life situation in which you participate in an audio or video conference, we recommend that you mute the microphone by default and blur the background or have a virtual background displayed.
We use in particular:
Microsoft Teams: Platform for audio and video conferencing, among other things; Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the UK and Switzerland; information on data protection: ‘Data protection’ (‘Microsoft Trust Centre’), privacy policy, ‘Data protection at Microsoft’, ‘Data protection and Microsoft Teams’.
Zoom: Video conferencing; Service provider: Zoom Video Communications Inc. (USA); Information on data protection: Privacy Policy, ‘Data protection at Zoom’, ‘Legal Compliance Centre’.
10.4 Social media functions and social media content
We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.
We use in particular:
Instagram platform: embedding Instagram content; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Privacy Policy (Instagram), Privacy Policy (Facebook).
LinkedIn Consumer Solutions Platform: Embedding functions and content from LinkedIn, for example with plugins such as the ‘Share Plugin’; Provider: LinkedIn Ireland Unlimited Company (Ireland) for users in the European Economic Area (EEA) and Switzerland / LinkedIn Corporation USA) for users in the rest of the world; Data protection information: ‘Privacy’, data protection declaration, cookie policy, cookie management / objection to e-mail and SMS communication from LinkedIn, objection to interest-based advertising.
10.5 Map material
We use third-party services to embed maps on our website.
We use in particular:
Google Maps including Google Maps Platform: map service; Google Maps-specific data protection information: ‘How Google uses location information’.
10.6 Audiovisual media
We use third-party services to enable the direct playback of audiovisual media such as music or videos on our website.
We use in particular:
Cloudflare Stream: video platform; provider: Cloudflare Inc (USA); information on data protection: ‘Data protection’, privacy policy, cookie policy.
SoundCloud: Music and podcasts (widget); Service provider: SoundCloud Global Limited & Co. KG (Germany); Privacy Policy: Privacy Policy, Cookie Policy.
Spotify: Music and podcasts (widget); Service provider: Spotify AB (Sweden); Privacy Policy: ‘Privacy Centre’, ‘Privacy Policy’.
Vimeo: Videos; Service provider: Vimeo Inc (USA); Privacy Policy: ‘Privacy Policy’, Privacy Policy.
YouTube: Videos; Provider: Google (among others in the USA); YouTube-specific data protection information: ‘Privacy and Security Centre’, ‘My Data on YouTube’.
10.7 Documents
We use third-party services to integrate documents into our website. Such documents may include, for example, forms, PDF files, presentations, tables and text documents.
We use in particular:
Microsoft 365 (also Microsoft Office 365): text documents as well as forms, presentations and tables; provider: Microsoft Corporation (USA); information on data protection: privacy policy, “Data protection at Microsoft”, “Data protection” (“Microsoft Trust Center”), “Data protection and security with Microsoft 365”.
10.8 E-Commerce
We operate e-commerce and use third-party services to successfully offer services, content or goods.
10.9 Payments
We use payment service providers to process our customers' payments securely and reliably. The terms and conditions of the relevant payment service providers, such as general terms and conditions or data protection declarations, apply to processing.
We use in particular:
Stripe: processing of payments; providers: Stripe Inc (USA) / Stripe Payments Europe Limited (SPEL, Ireland) for users in the European Economic Area (EEA) and Switzerland and partly in the UK / Stripe Payments UK Limited (UK) and Stripe Capital Europe Limited (Ireland) partly for users in the UK; information on data protection: “Stripe Privacy Center” (“Stripe Privacy Center”), privacy policy, cookie policy.
11. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
In particular, we use:
Google reCAPTCHA: Spam protection (differentiation between desired comments that come from humans and unwanted comments from bots and spam); Google reCAPTCHA-specific data protection information: “What is reCAPTCHA?” (“What is reCAPTCHA?”).
12. Final provisions
We have created this privacy policy using the privacy policy generator from Datenschutzpartner.
We can adapt and supplement this privacy policy at any time. We will provide information about such amendments and additions in an appropriate form, in particular by publishing the current privacy policy on our website.