§ 1 Information about the collection of personal data
(1) In the following we provide information about the collection of personal data when using our website. Personal data means any data that refers to you specifically, e. g. your name, address, email addresses and user behavior.
(2) The ‘Controller’ according to Article 4 (7) of the EU General Data Protection Regulation (GDPR) is Listan GmbH, Biedenkamp 3A, 21509 Glinde, Germany (see Imprint). You can contact our Data Protection Officer at
Dr. Volker Wodianka, LL.M.
Certified Data Protection Officer (CIPP/E, CIPM, GDDcert.)
c/o SCHLUTIUS Data Privacy & Compliance GmbH
or by writing to our postal address with the addition “The Data Protection Officer.”
(3) When you make contact with us by email or use our contact form we will store the data you enter (your email address, your name and your telephone number) in order to reply to your query. The data you disclose to us in this connection is deleted as soon as it is no longer required, or after a statutory period of retention, as applicable.
(4) When it is necessary to use the services of contracted providers to provide specific features on our website or we wish to use your data for promotional purposes, we will inform you in detail below about the respective processes. We will also specify the fixed criteria for retention periods.
§ 2 Your rights
(1) You have the following rights with respect to our use of your personal data:
- Right of access,
- Right to rectification or erasure,
- Right to restriction of processing,
- Right to object,
- Right to data portability.
(2) You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us. For this purpose you can contact the supervisory authority for our company location in Schleswig-Holstein. You will find the address on the internet using the following link:
§ 3 Personal data we collect when you visit our website
(1) When you view our website simply to obtain information, without registering or providing us with further information in any other way, we only collect the personal data your browser transfers to our server. When you view our website we collect the following items of data, which for us to display our website to you are technically necessary and ensure its stability and security (legal basis is Article 6 (1) point (f) of the GDPR):
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Contents of the request (particular page)
- Access status/HTTP status code
- Volume of data transmitted
- Webpage the request was referred from
- Operating system and web interface
- Browser software language and version.
These items of data are only stored for one week and then automatically deleted, with the exception of the IP address. This we save for a month, in order to investigate in retrospect in cases of a cyber-attack whether our internal systems were compromised.
(2) In addition to the data previously mentioned, when using our website cookies will be stored on your device, provided you consented to this. Cookies are small text files that are stored in a folder on your hard drive assigned by the browser you used and in which certain information is gathered (in this case as determined by us). With cookies it is not possible to execute a program or plant a virus on your device. They simply serve to make our website generally more user friendly and effective.
a) This website uses the following types of cookies, whose scope and functionality are explained in the following:
- Transient cookies (see b)
- Persistent Cookies (see c).
b) Transient cookies are deleted automatically when your browser is closed. In particular these include session cookies. These store what is known as a session ID and this enables a series of requests from your browser to be treated as a single session. This makes it possible to recognize your device as you continue to use our website. Session cookies are deleted when you log out or when you close your browser.
c) Persistent cookies are automatically deleted after a predetermined expiry date, which is determined individually for each cookie. You can remove cookies at any time by using the security configuration options of your browser.
d) You can configure your browser settings as desired and, for example, refuse to accept third-party cookies or refuse any cookie. Please note that doing so could restrict your use of our website.
e) Flash cookies used are not recorded by your browser, but instead by your Flash plugin. We also use HTML5 storage objects, which are stored on your device. These objects store data independently to the browser you use and have no automatic expiry date. If you do not want to process Flash cookies it is necessary to install an appropriate add-on, e. g. “Cookiebro” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/cookiebro/) or the “Adobe Flash Cookie Killer” for Google Chrome. You can prevent the use of HTML5 storage objects by opening our website in a private window in your browser. We recommend that you routinely delete cookies and browser history manually from time to time.
§ 4 Additional functions and facilities of our website
(1) As well as the pure informational use of our website we offer various services that you can use if you are interested. As a rule you these require you to enter further personal data that we use to provide the respective service and for which the aforementioned principles of data protection apply.
(2) In some cases we use external service providers for processing your data. These suppliers are carefully selected and contracted by us, they are bound by our instructions and are regularly checked.
(3) In addition we may forward your personal data to third parties when promotions, competitions, contract conclusions or similar services are offered by us jointly with partners. You will obtain further information about this where you enter your personal data or below the description of the offer.
(4) When our service providers or partners are based in a country outside the European Economic Area (EEA) we will inform you of the implications of this circumstance in the description of our offer.
§ 5 Competitions
When we offer entry to a competition then we collect the personal data of participants, but purely for the purposes of conducting the competition. In this case the following information is obtained: last name, first name, date of birth, postal address, email address, IP address, telephone number. These items of data are necessary for age verification, communications, fraud detection and possibly the posting of a prize. This information is not given to third parties, unless when necessary for the purposes of informing a forwarding company to deliver a prize. After the competition is over the data is deleted, unless there is a mandatory period of retention.
§ 6 Newsletter
(1) You can give your consent by requesting our newsletter, with which we inform you about our latest and interesting offers. In the consent form it explains this is a promotion of goods and services.
(2) For registrations to our newsletter we use what is known as the double opt-in procedure. This means that after you apply online, we send an email to the email address you entered, within which we ask you to confirm your desire to receive newsletters. If we do not receive a confirmation within [24 hours], the information in your application is blocked and after a month is automatically deleted. Furthermore, we store the IP addresses used and the dates and times of registration and confirmation. The purpose of this is to provide evidence of your registration and, should it prove necessary, the ability to investigate possible abuses of your personal information.
(3) The only entry that is compulsory for receiving newsletters is your email address. The entry of further so designated fields is voluntary, but which enable us to address you in person. After your confirmation, we store your email address for the purposes of sending you newsletters. Legal basis is Article 6 (1) point (a) of the GDPR.
(4) Your consent for receiving newsletters may be revoked at any time and the newsletter unsubscribed. Revocation can be achieved by a click on a link included in the email of every newsletter or by writing to us declaring your wish to unsubscribe using any of contact options in the Imprint.
(5) Please note that when you read our newsletter we analyze your usage behavior. In order to achieve this analysis the email contains what are known as web beacons or pixel tags, which loads an image file consisting of a single pixel that is stored on our website. We combine the data specified in § 3 with the web beacon, your email address and an ID uniquely allocated to you. The links contained in the newsletter also refer to this ID. Using this information we compile a user profile, which enables us to tailor our offers to your individual interests. We also record when you read our newsletter, which links inside it you click on and deduce from this what interests you. We combine this information with your activity while using our website. You may object to this tracking at any time, by contacting us. This information is stored for as long as you are subscribed for the newsletter. After you unsubscribe we store the information statically and anonymously. Such tracking is not possible if you have configured your email client to not show images by default. In that case the newsletter is not entirely displayed and you will perhaps not be able use all of its functions. When you manually override this setting and permit images to be shown, the tracking described above will proceed.
§ 7 Refusal or withdrawal of your permission for processing your data
(1) If you have given your permission for us to process your data, you can withdraw it at any time. Such a withdrawal influences whether processing of your personal data is permissible once you have notified us.
(2) If we justify the processing of your personal data by weighing interests, you can refuse processing. This is particularly the case when processing is not required to fulfil a contract with you, which we outline along with a description of the function. When exercising such a refusal, we ask you to provide reasons why you do not wish us to process your personal data as we normally do. If your refusal is justified, we will review the current situation and either cease or adjust our data processing, or will provide you with compelling and legitimate grounds for our continuing to do so.
(3) You can of course object to processing of your personal data for purposes of advertising and data analysis at any time. You can inform us of any objections you have to advertising by writing an email to: [email protected]
§ 8 Use of Google Analytics
(1) This website, provided you give your consent, uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses what are known as “cookies”, which are text files that are saved on your device and permit analysis of your use of the website. The information generated by the cookie about your use of this website is normally transferred to and saved on a Google server in the USA. If this website uses IP anonymization, your IP address is truncated in advance by Google within the Member States of the European Union or other signatories of the European Economic Area. Only in exceptional cases is a full IP address transferred to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate use of the website, to summarize reports about website activity and to provide other services associated with the usage of the website and the internet for the website operator.
(2) The IP address transferred by the browser as a part of Google Analytics is not combined with other data by Google.
(3) You can prevent cookies being saved with the appropriate setting in your browser software; however, please note that in this case you may not be able to use all the functions of this website. Furthermore, you can prevent Google collecting and processing the data related to your use of the website recorded by the cookie (incl. your IP address), by downloading and installing a browser plugin that is available using the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
(4) This website uses Google Analytics with the extension “_anonymizeIp()”. This forces IP addresses to be abbreviated before they are processed, preventing any personal attribution. Insofar as any data could be attributed to a person, such personal data is excluded and deleted immediately.
(5) We use Google Analytics in order to analyze the usage of our website and improve it regularly. The statistics we obtain help us to improve our offer and make it more interesting for you as user. For the exceptional cases when items of personal data are sent to the USA, Google has signed up to the EU-US Privacy Shield, see https://www.privacyshield.gov/EU-US-Framework. Legal basis for the use of Google Analytics is Article 6 (1) point (f) of the GDPR.
(6) Third-party provider details: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
Terms and conditions of use: http://www.google.com/analytics/terms/us.html
Privacy and terms: https://policies.google.com/?hl=en
(7) This website uses Google Analytics to analyze visitor traffic across devices via a user ID. You can deactivate analysis of your usage across devices in your Google-customer account under “My Data” / “Personal Data”.
§ 9 Chat function
When you make contact with us with the website’s chat function, this is achieved using the live chat software of the company Userlike UG (limited liability) based in Cologne. When you start to use this feature on the website, a connection is established with the servers of Userlike UG. In so doing Userlike will store your IP address and – provided you have consented to this – save cookies on your device in order to make a personal conversation with you possible in the form of a real time chat on the website. You can prevent the saving of cookies by withdrawal of your consent or with the respective settings in your browser software; in that case it is possible that the full scope of the chat feature and other functions of this website may no longer be available to you. The following data is collected, processed and stored:
- Content of the chat
- Date and time of starting
- Browser type and version
- Operating system used
- URL of referrer webpage
- Amount of data transferred.
The data collected will not be used to personally identify the visitor to this website and not combined with personal data on the bearer of a pseudonym. The data will also be stored by Userlike UG. We delete the data we keep after six weeks. Further information about how Userlike UG conforms to the data protection regulations can be learned by viewing the privacy notice of Userlike UG at https://www.userlike.com/en/terms#privacy-policy.
§ 10 Social media
1. Integration of YouTube videos
(1) We have, provided you granted your consent, embedded YouTube videos into our website that are stored on https://www.YouTube.com and can be played directly on our webpages. These videos are all embedded using “Extended Data Protection Mode”, which means no data about you is transmitted to YouTube unless you play the videos. Only then will the data described in § 3 be transmitted. We have no influence over this data transfer.
(2) By your viewing YouTube will be informed that the corresponding page of our website was visited. The data mentioned in § 3 is then transmitted. This will occur regardless of whether you are logged in to a YouTube user account or if you have no user account. If you are logged into Google, your data will be directly assigned to your account. If you don’t want the information assigned directly to your profile with YouTube, you will have to log out before activating the play button. YouTube stores your data as a usage profile and uses it for advertising, market research, and user-friendly configuration of its website. Such evaluation serves (as well as for users who are not logged in) the purpose of providing customized needs-based advertising and in order to inform other users in the social network of your activities on our website. You have the right to deny permission for such a user profile to be formed, but in order to assert this right you must contact YouTube.
(3) Further information on the purpose and scope of data collection and its processing by YouTube can be found in its data protection declaration. There you will also receive further information on your rights and setting options for protecting your privacy: https://policies.google.com/privacy?hl=en. Google also processes your personal data in the United States and has agreed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
2.) Facebook fan page
We run our official Facebook fan page at www.facebook.com/bequietenglish. The technical provider for it is Facebook Inc., located at 1601 S. California Avenue, Palo Alto, CA 94304, USA. Facebook utilizes a tool called “Page Insights” to provide information regarding, amongst other things, reach and interaction rates of the fan page. Find detailed information about the functionality of “Page Insights” here.
Based on a verdict by the European Court of Justice from June 5th 2018 (Az. C-210/16) we share responsibility for the contents on our fan page with Facebook. According to article 26 GDPR this leads to an agreement between Facebook and ourselves, a so called “Joint Controllership”. Find detailed information about this agreement here.
Legal basis for the handling and processing of personal data by the “Page Insights” tool is article 6, paragraph 1, lit. f of GDPR. The responsible supervisory authority for user complaints about our Facebook fan page is, in compliance with the abovementioned agreement, the Irish Data Protection Commission.
§ 11 Online advertising
1. Use of Google AdWords Conversion
(1) We use the services of Google Adwords, provided you grant your consent, to bring attention to our attractive offers with ads (known as Google Adwords) on external websites. We can determine from data about our ad campaigns the success of individual advertising measures. We do this in the interests of showing you ads that are of interest to you, to make our website more interesting for you and to achieve a fair reckoning of advertising costs.
(2) Google delivers these ads with what are known as “ad servers”. We also use ad server cookies from which we determine certain parameters of success, such as the placement of ads or clicks by the user. If you come to our website from a Google ad, Google Adwords will save a cookie on your device. These cookies usually lose their validity after 30 days and are not intended to identify you personally. Stored inside this cookie are analysis data such as a unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (indication that the user no longer wants to be targeted).
(3) These cookies enable Google to treat your browser views as a session. If a user visits certain pages of the website of an AdWords customer and the cookie stored on his computer has not yet expired, Google and the customer can tell that the user clicked on the ad and was redirected to the page. A different cookie is assigned for every AdWords customer. Cookies cannot be tracked by the websites of AdWords customers. We ourselves do not collect or process any personal data using these advertising measures. We only receive statistical analyses made available by Google. With these analyses we are able to determine which of our advertising measures are especially effective. We do not receive any further data about the use of advertisements and, in particular, we are unable to identify users on the basis of this data.
(4) Due to the nature of the marketing tool, your browser automatically establishes a direct connection with Google’s server. We have no influence over the scope and further use of data collected from Google’s use of this tool and therefore the following information reflects our current knowledge: By the integration of AdWords Conversion, Google receives the information that you have visited that part of our website or clicked on one of our ads. If you are registered for a Google service, Google is able to attribute the visit to your account. If you are not registered with Google or are not logged in, it remains possible for the provider to discover and store your IP address.
(5) You can inhibit participation in this tracking process in several ways: a) by changing the settings in your browser software, in particular, suppression of third-party cookies will mean you no longer receive ads from third-party vendors; b) by deactivating the cookies for conversion tracking by configuring your browser in such a way that cookies from the domain “googleadservices.com” are blocked (see https://adssettings.google.com), however, such blocking is lost if you delete all cookies; c) by deactivating the vendor’s interest-themed ads that are part of the DAA self-regulation campaign “Web Choices” (see http://optout.aboutads.info/?c=2&lang=EN) , however, this option is lost if you delete all cookies; d) by permanent deactivation plugin for browsers Firefox, Internet Explorer and Google Chrome available at https://support.google.com/ads/answer/7395996?hl=en. Please note that if you do this you may not be able to use all features of this website to their full extent.
(6) The legal basis for processing your data is Article 6 (1) point (f) of the GDPR. You can find additional information about Google’s data protection policies here: https://policies.google.com/privacy?hl=en and https://services.google.com/sitestats/en.html. Alternatively, visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org. Google has signed up to the EU-US Privacy Shield, see https://www.privacyshield.gov/EU-US-Framework.