Privacy Policy

1. Privacy Overview

General Information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any information that can be used to identify you personally. Detailed information on the subject of data protection can be found in our Privacy Policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. You can find their contact details in the section “Notice of Responsible Entity” in this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us. For example, this can be data that you enter in a contact form.

Other data is collected automatically or with your consent when you visit the website through our IT systems. These are primarily technical data (e.g., internet browser, operating system, or time of page access). The collection of this data occurs automatically as soon as you enter this website.

How do we use your data?

Some of the data is collected to ensure the proper functioning of the website. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other inquiries.

What rights do you have regarding your data?

You have the right to receive free information about the origin, recipient, and purpose of your stored personal data at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. Additionally, you have the right to lodge a complaint with the responsible supervisory authority.

For this purpose and for further questions on the topic of data protection, you can contact us at any time.

Analysis Tools and Third-Party Tools

When visiting this website, your surfing behavior may be statistically evaluated. This is mainly done using analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting

We host the content of our website with the following provider:

External Hosting

This website is externally hosted. The personal data collected on this website is stored on the servers of the host/hosting provider. This may include, but is not limited to, IP addresses, contact inquiries, meta and communication data, contract data, contact details, names, website accesses, and other data generated through a website.

The external hosting is done for the purpose of fulfilling contracts with our potential and existing customers (Art. 6 Para. 1 lit. b GDPR) and in the interest of providing our online offering securely, quickly, and efficiently by a professional provider (Art. 6 Para. 1 lit. f GDPR). If consent has been requested, the processing takes place exclusively based on Art. 6 Para. 1 lit. a GDPR and § 25 Para. 1 TDDDG, to the extent that the consent includes the storage of cookies or access to information on the user’s end device (e.g., device fingerprinting) according to TDDDG. The consent can be revoked at any time.

Our hosting provider will process your data only to the extent necessary to fulfill their service obligations and follow our instructions regarding this data.

We use the following hosting provider: Hostinger

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection laws, which ensures that the personal data of our website visitors is processed only according to our instructions and in compliance with the GDPR.

3. General Notes and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations as well as this privacy policy.

When you use this website, various personal data is collected. Personal data is information that can be used to identify you personally. This privacy policy explains which data we collect and how we use it. It also explains how and for what purpose this is done.

We point out that data transmission over the internet (e.g., when communicating via email) can have security vulnerabilities. A complete protection of the data from access by third parties is not possible.

Notice of Responsible Entity

The responsible entity for data processing on this website is:

M. Theresia
Perumahan Hunian Asri Blok F15
Sulawesi Utara, Indonesia
Email: support@study25m.com

The responsible entity is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Storage Duration

Unless a more specific storage period is stated in this privacy policy, your personal data will remain with us until the purpose for data processing ceases to apply. If you submit a justified request for deletion or revoke consent for data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial retention periods); in the latter case, deletion will take place after the reason for retention ceases to apply.

General Notes on the Legal Basis for Data Processing on This Website

If you have given consent to data processing, we process your personal data based on Art. 6 Para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR if special categories of data are processed according to Art. 9 Para. 1 GDPR. In case of explicit consent to the transfer of personal data to third countries, the data processing also takes place based on Art. 49 Para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information on your end device (e.g., via device fingerprinting), data processing also occurs based on § 25 Para. 1 TDDDG. Consent can be revoked at any time. If your data is necessary for the performance of a contract or for the execution of pre-contractual measures, we process your data based on Art. 6 Para. 1 lit. b GDPR. Furthermore, we process your data if required for the fulfillment of a legal obligation based on Art. 6 Para. 1 lit. c GDPR. Data processing may also be based on our legitimate interest according to Art. 6 Para. 1 lit. f GDPR. The specific legal basis for each processing case will be provided in the following sections of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we cooperate with various external entities. In some cases, it is necessary to transfer personal data to these external entities. We only pass on personal data to external entities if this is necessary for the fulfillment of a contract, if we are legally obligated to do so (e.g., data transfer to tax authorities), if we have a legitimate interest according to Art. 6 Para. 1 lit. f GDPR in the transfer, or if another legal basis permits the data transfer. When using processors, we only transfer personal data of our customers based on a valid contract for data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke your already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. YOU CAN FIND THE LEGAL BASIS FOR THE PROCESSING IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION UNDER ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING PURPOSES; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION UNDER ART. 21 PARA. 2 GDPR).

Right to Lodge a Complaint with the Supervisory Authority

IN THE EVENT OF A VIOLATION OF THE GDPR, DATA SUBJECTS HAVE THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY, PARTICULARLY IN THE MEMBER STATE OF THEIR USUAL RESIDENCE, PLACE OF WORK, OR THE LOCATION OF THE ALLEGED INFRINGEMENT. THIS RIGHT TO LODGE A COMPLAINT DOES NOT AFFECT OTHER ADMINISTRATIVE OR JUDICIAL REMEDIES.

Right to Data Portability

You have the right to have data which we process automatically based on your consent or in the performance of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of data to another controller, this will only be done to the extent technically feasible.

Right to Information, Correction, and Deletion

WITHIN THE FRAMEWORK OF THE APPLICABLE LAWS, YOU HAVE THE RIGHT TO RECEIVE FREE INFORMATION ABOUT YOUR STORED PERSONAL DATA, ITS ORIGIN AND RECIPIENT, THE PURPOSE OF THE DATA PROCESSING, AND IF APPLICABLE, THE RIGHT TO CORRECT OR DELETE THIS DATA. YOU CAN CONTACT US AT ANY TIME FOR FURTHER QUESTIONS REGARDING PERSONAL DATA.

Right to Restrict Processing

You have the right to request the restriction of processing your personal data. You can contact us at any time. The right to restrict processing applies in the following cases:

If you dispute the accuracy of the personal data we have stored, we generally need time to verify this. During the verification period, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend, or establish legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have filed an objection under Art. 21 para. 1 GDPR, a balance must be made between your and our interests. As long as it is not yet clear whose interests outweigh, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data has been restricted, this data – except for its storage – may only be processed with your consent, or for the establishment, exercise, or defense of legal claims, or to protect the rights of another natural or legal person, or for reasons of significant public interest of the European Union or a Member State.

SSL/TLS Encryption

This site uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries you send to us as the site operator. You can recognize an encrypted connection by the address line of your browser changing from “http://” to “https://” and by the lock symbol in your browser’s address bar.

When SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Advertising Emails

The use of contact details published in the context of the imprint obligation for sending unsolicited advertising and informational materials is hereby objected to. The site operators expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam emails.

4. Data Collection on This Website

Cookies

Our websites use so-called “cookies”. Cookies are small data packets and do not harm your device. They are either temporarily stored for the duration of your session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Persistent cookies remain on your device until you delete them or they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third parties (third-party cookies). Third-party cookies allow the integration of certain services from third parties within websites (e.g., cookies for processing payment services).

Cookies serve various purposes. Many cookies are technically necessary because certain website features would not function without them (e.g., shopping cart functionality or displaying videos). Other cookies may be used for analyzing user behavior or for advertising purposes.

Cookies that are necessary for the execution of electronic communication processes, for providing certain features requested by you (e.g., for the shopping cart function), or for optimizing the website (e.g., cookies to measure web traffic) are stored based on Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of their services. If consent for storing cookies and similar recognition technologies has been requested, processing will only take place based on that consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG); consent can be revoked at any time.

You can configure your browser to be notified about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for specific cases or generally, and activate the automatic deletion of cookies when closing the browser. If cookies are disabled, the functionality of this website may be restricted.

Which cookies and services are used on this website can be found in this privacy policy.

Contact Form

If you send us inquiries via contact form, your information from the inquiry form, including the contact details you provided, will be stored by us for the purpose of processing the request and for any follow-up questions. We will not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, as long as your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing the inquiries sent to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR), if it has been requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request its deletion, withdraw your consent for storage, or the purpose for the data storage no longer applies (e.g., after the completion of your request). Mandatory legal provisions – particularly retention periods – remain unaffected.

Inquiry via Email, Phone, or Fax

If you contact us by email, phone, or fax, your inquiry, including any personal data (name, inquiry), will be stored and processed by us for the purpose of handling your request. We will not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, if your inquiry is related to the fulfillment of a contract or necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or your consent (Art. 6 para. 1 lit. a GDPR), if this was requested; consent can be revoked at any time.

The data you send to us via contact inquiries will remain with us until you request its deletion, revoke your consent for storage, or the purpose for data storage no longer applies (e.g., after your inquiry has been processed). Mandatory legal provisions—especially statutory retention periods—remain unaffected.

5. Social Media

Instagram

This website integrates features of the Instagram service. These features are offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

If the social media element is active, a direct connection will be established between your device and the Instagram server. This allows Instagram to receive information about your visit to this website.

If you are logged into your Instagram account, you can link the contents of this website to your Instagram profile by clicking the Instagram button. This allows Instagram to associate your visit to this website with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or how Instagram uses this data.

The use of this service is based on your consent according to Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDG. Consent can be revoked at any time.

As far as personal data is collected on our website with the help of the tool described here and transferred to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited to the collection of data and its transfer to Facebook or Instagram. The processing that occurs after the transfer by Facebook or Instagram is not part of the joint responsibility. The obligations we jointly have are laid out in an agreement on joint processing. You can find the wording of the agreement here: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the data protection information when using the Facebook or Instagram tool and for the data protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert your rights (e.g., access requests) regarding data processed by Facebook or Instagram directly with Facebook. If you assert your rights with us, we are obligated to forward them to Facebook.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381.

For more information, please refer to Instagram’s privacy policy: https://privacycenter.instagram.com/policy/.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards in data processing in the USA. Any company certified under the DPF commits to adhering to these data protection standards. More information can be found at the provider’s link: https://www.dataprivacyframework.gov/participant/4452.

6. Newsletter

Newsletter Data

If you wish to subscribe to the newsletter offered on the website, we require your email address as well as information that allows us to verify that you are the owner of the provided email address and that you agree to receive the newsletter. No further data will be collected, or only on a voluntary basis. We use this data solely for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form is solely based on your consent (Art. 6 para. 1 lit. a GDPR). The consent granted for storing the data, the email address, and its use for sending the newsletter can be revoked at any time, for example via the “unsubscribe” link in the newsletter. The legality of the already processed data remains unaffected by the withdrawal.

The data you have provided for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter or the purpose for storing the data no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our discretion, within our legitimate interest under Art. 6 para. 1 lit. f GDPR.

Data stored for other purposes remains unaffected by this.

After unsubscribing from the newsletter distribution list, your email address may be stored in a blacklist by us or the newsletter service provider, if necessary, to prevent future mailings. Data in the blacklist is used only for this purpose and is not combined with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest under Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is not time-limited. You can object to the storage if your interests outweigh our legitimate interest.

Newsletter Sending to Existing Customers

If you have ordered goods or services from us and provided your email address, this email address may subsequently be used by us for sending newsletters, provided we have informed you in advance. In this case, the newsletter will only contain direct advertising for similar goods or services of our own. You may unsubscribe from this newsletter at any time. For this purpose, each newsletter contains a corresponding link. The legal basis for sending the newsletter in this case is Art. 6 para. 1 lit. f GDPR in connection with § 7 para. 3 UWG.

After unsubscribing from the newsletter distribution list, your email address may be stored in a blacklist by us to prevent future mailings. The data in the blacklist will only be used for this purpose and will not be combined with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest under Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is not time-limited. You may object to the storage if your interests outweigh our legitimate interest.

7. Plugins and Tools

YouTube with Extended Privacy

This website integrates videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit a page on this website where YouTube is embedded, a connection to the YouTube servers will be established. This will inform the YouTube server about which page of ours you have visited. If you are logged into your YouTube account, YouTube will be able to directly associate your browsing behavior with your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended privacy mode. Videos played in extended privacy mode, according to YouTube, are not used to personalize the browsing experience on YouTube. Ads served in extended privacy mode are also not personalized. In extended privacy mode, no cookies are set. However, local storage elements are stored in the user’s browser, which, similar to cookies, contain personal data and can be used for recognition. Details about extended privacy mode can be found here: https://support.google.com/youtube/answer/171780.

After activating a YouTube video, further data processing may occur, which we cannot influence.

Using YouTube serves the purpose of presenting our online offerings in an appealing way. This constitutes a legitimate interest under Art. 6 para. 1 lit. f GDPR. If consent was requested, the processing is solely based on Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent involves the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.

Further information about data protection on YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=en.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards in data processing in the USA. Any company certified under the DPF commits to adhering to these privacy standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Fonts (Local Hosting)

This site uses Google Fonts, which are provided by Google, to display fonts consistently. The Google Fonts are installed locally. No connection to Google servers is made in this case.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is used to check whether data input on this website (e.g., in a contact form) is made by a human or an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the site. To analyze, reCAPTCHA evaluates various information (e.g., IP address, time spent on the site, or mouse movements made by the user). The data collected during the analysis is transmitted to Google.

The reCAPTCHA analysis runs entirely in the background. Website visitors are not notified that an analysis is taking place.

The storage and analysis of the data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its online services from abusive automated scraping and spam. If consent was requested, the processing is solely based on Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent involves the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.

Further information on Google reCAPTCHA can be found in Google’s privacy policy and terms of use at the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

Source: https://www.e-recht24.de