Privacy policy

We take data protection seriously. The collection and processing of your personal data is carried out in accordance with the data protection regulations in force, in particular the EU General Data Protection Regulation (GDPR). We collect and process your personal data to offer you our website and our services. In accordance with Art. 13 GDPR, we describe in this declaration which data is used by us in which way and for what purpose and scope and which options and rights you have regarding the use of your personal data.

Responsibility

Limbus Medical Technologies GmbH, Schillerplatz 1, 18055 Rostock, Germany, is responsible for compliance with data protection on our site.

Data protection officer:Roland Ewald, dpo@limbus-medtec.com

Feel free to contact us for data protection inquiries.

Contact:
  +49 381 2550 062-0

The varvis® Academy is hosted by LearnWorlds (CY) Ltd, Gladstonos 120, Foloune Building, 2nd Floor, B1, Limassol, 3032, Cyprus. They provide us with the online platform that allows us to provide and sell our courses/services to you. Your data is collected and stored through Learnworld's data storage, databases and the general LearnWorlds applications.

Learnworlds offers further data protection information at https://www.learnworlds.com/privacy-policy/.

Data collection on our website

Server log files

When you access our varvis® academy, information is automatically transmitted by your browser to the server of our platform provider Learnworlds. This information is stored, processed and deleted in an automated way according to the LearnWorlds' policies.

This includes the following data:
  • Your IP address,
  • Location,
  • Date and time of the page visit,
  • Name and URL of the file you are accessing,
  • Website from which the call is made (referrer URL),
  • Information about the used browser and operating system,
  • Name of your access provider.

This data is used for the purpose of ensuring a smooth connection and comfortable use of our website as well as to evaluate system security and stability.

The legal basis for the data processing derives from Art. 6 para. 1 S. 1 lit. f GDPR, as we have a legitimate interest in collecting data for the above-mentioned purposes. In addition, a legal basis also results from Art. 6 para. 1 lit. b GDPR for the processing of data for the fulfilment of a contract or pre-contractual measures.

The data will not be used to draw conclusions about your person.

Registration

In order to be able to access the courses and contents of the varvis® academy, you have to register and create an account. During the registration process you have to enter your name and e-mail address, which will then, together with other optional data that you may enter, be transmitted to us. Your IP address and the date and time of registration are also used.

For the processing of the data, your consent will be obtained during the registration process and reference will be made to this data  protection declaration. The legal basis for the processing of the data after registration to the varvis
® academy by the user is Art. 6 para. 1 lit. a GDPR if the user has consented.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for as long as you keep an account with our platform or it is required according statutory warranty or retention periods.

In the profile settings of your varvis® academy profile you have the possibility to adjust and change your personal information and privacy settings. You also have the possibility to delete your account there, in which case all your associated data will be deleted, depending on the kind of data either immediately or after the expiry of the statutory warranty periods or after the end of statutory retention periods.

Courses and subscriptions

After registering to the varvis® academy you will be able to subscribe and enroll in our courses. When enrolling and taking courses, information about your learning history, such as assigned courses, scores and test status and certificates, will be automatically stored with your account and transmitted to us. This also applies to information about your subscription such as subscription plan, status and expiration date.

The legal basis for the processing of the data after enrolling to a course or subscription of the varvis
® academy by the user is Art. 6 para. 1 lit. a. Additionally, the data is collected for the purpose of initiating or implementing contractual relationships in accordance with Art. 6 para. 1 lit. b GDPR.

Inbox / Contact form / Communication by email

On our learning school you will find an Inbox where we want to give our learners a possibility to contact us, trainers or other users in an uncomplicated way. You can also contact us directly by e-mail. If you use the Inbox, your messages will be stored with your account. When contacting us via Inbox, your username and profile will be directly forwarded to us. If you send us an e-mail, we will at least receive your e-mail address. All other data given is optional. Data is collected for the purpose of initiating or implementing contractual relationships in accordance with Art. 6 para. 1 lit. b GDPR. Insofar as your enquiry is not directed at initiating or implementing a contract, we nevertheless have a justified interest in processing and answering your enquiry. In this respect, the use of personal data for this purpose is governed by Art. 6 para. 1 lit. f GDPR.

We use the data you provide exclusively to process your inquiry. Insofar as your enquiry is directed towards the initiation or execution of business, we will delete your data in accordance with our internal deletion periods. 
Insofar as your inquiry is related to another purpose, we will delete your data after processing if there is no other legal basis for data storage.

Such personal data that you voluntarily provide to us via email will be stored in our customer relationship management system FreshSales, a service of Freshworks, Inc., 2950 S.Delaware Street, Suite 201, San Mateo, CA 94403 for the purpose of processing or contacting you. In addition, the date and time of the contact is stored.

Freshworks also offers further data protection information at
https://www.freshworks.com/freshsales-crm/privacy/.

Subject to legal or contractual permissions, we allow Freshworks to process the data in a third country under the special conditions of Art. 44 et seq. GDPR. Freshworks has submitted to the GDPR. This means that processing is carried out in compliance with officially recognized special contractual obligations (so-called "Standard Contractual Clauses").

Processing of customer and contract data

When initiating business, concluding and fulfilling a contract, we use your personal data necessary for this purpose in accordance with Art. 6 Para. 1 lit. b GDPR. Data will only be transferred to third parties if and insofar as this is necessary for contractual fulfilment, e.g. if a company has been commissioned for production or transport services or a credit institution has been commissioned to process payments. The deletion of this personal data takes place after the expiry of the statutory warranty periods or after the end of statutory retention periods unless you have expressly consented to their further use.

Newsletter

On our website you have the possibility to subscribe to a free newsletter for the purpose of direct advertising. When registering for the newsletter, your e-mail address and other optional data from the input mask will be transmitted to us. Your IP address and the date and time of registration are also used. The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used.

For the processing of the data, your consent will be obtained during the registration process and reference will be made to this data protection declaration. The legal basis for the processing of the data after registration for the newsletter by the user is Art. 6 para. 1 lit. a GDPR if the user has given his consent. 
The data will be deleted as soon as they are no longer required for the purpose of their collection. The user's e-mail address is therefore stored for as long as the subscription to the newsletter is active.

The e-mail is sent via "MailChimp", a newsletter platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The data protection regulations of the mail service provider can be viewed here:
https://mailchimp.com/legal/privacy/
Subject to legal or contractual permissions, we allow MailChimp to process the data in a third country under the special conditions of Art. 44 et seq. GDPR. MailChimp has submitted to the GDPR. This means that processing is carried out in compliance with officially recognized special contractual obligations (so-called "Standard Contractual Clauses").

Our newsletters sent via The Rocket Science Group contain so-called web beacons. A web beacon is a thumbnail image embedded in e-mails sent in HTML format to allow log file recording and analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns. By means of the embedded pixel-code, we can see whether and when you have opened an e-mail and which links in the e-mail you have called up.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by The Rocket Science Group in order to enable us to optimize the newsletter dispatch and to improve the content of future newsletters to match your interests. The data is only used to improve the quality and attractiveness of our newsletter offer. This personal data is not passed on to third parties. You are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After a revocation, this personal data will be deleted. We automatically interpret a cancellation of the receipt of the newsletter as a revocation.

Furthermore, MailChimp may use this data itself on the basis of its own legitimate interest in the needs-based design and optimization of the service as well as for market research purposes, for example to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.

Zoom

For the best support and learning experience, we regularly offer live Q&A sessions and online meetings as part of our courses. For this purpose we use the tool Zoom, a service of Zoom Video Communications Inc., 55 Almaden Blvd, San Jose, California 95113, USA. You can view the privacy policy of the service provider here: https://zoom.us/privacy

If you want to attend one of these online meetings you have to register by entering you first name, last name and email address. All other personal user data given is optional. 
Additionally, meeting metadata such as topic, description (optional), participant IP addresses and device/hardware information are transmitted. If you dial-in via telephone, information on the incoming and outgoing call number, country name and start and end time will be processed. If necessary, further connection data such as the IP address of the device can be stored.
During the online meeting, you have the opportunity to use the chat function. In this case, the text entries you make are transmitted and saved by us for the purpose to process your enquiry and follow up on it afterwards.

In order to enable the display of video and the playback of audio, the data from the microphone and video camera of your device are processed accordingly during the meeting. You can switch off or mute the camera or microphone yourself at any time via the Zoom applications.

In some cases we record online meetings to provide them to the registrants afterwards. We will then transparently inform you in advance. It is also displayed in the Zoom applications if a meeting is recorded. 

The legal basis for the processing of the data after registration to the online meeting by the user is Art. 6 para. 1 lit. a GDPR if the user has given his consent and our legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. 

Subject to legal or contractual permissions, we allow Zoom to process the data in a third country under the special conditions of Art. 44 et seq. GDPR. Zoom has submitted to the GDPR. This means that processing is carried out in compliance with officially recognized special contractual obligations (so-called "Standard Contractual Clauses").

Zapier

For the integration of Mailchimp and FreshSales, we use Zapier, a service of Zapier Inc, 548 Market St #62411, San Francisco, California 94104, USA. In the process, the data entered for contacting, webinar or newsletter registration is transmitted. You can view the privacy policy of the service provider here: https://zapier.com/privacy.

Your consent is obtained for the processing of the data within the scope of the contact or registration process and reference is made to this privacy policy. The legal basis for the processing of the data after registration or contact by the user is Art. 6 para. 1 lit. a GDPR if the user has given his consent and our legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

Subject to legal or contractual permissions, we allow Zapier to process the data in a third country under the special conditions of Art. 44 et seq. GDPR. Zapier has submitted to the GDPR. This means that processing is carried out in compliance with officially recognized special contractual obligations (so-called "Standard Contractual Clauses").

Youtube - No Cookies

Based on your consent (in the sense of Art. 6 para. 1 lit. a GDPR), we use the provider YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, for the integration of videos on our site on the basis of Art. 6 para. 1 S. 1 lit. f GDPR. This is done for the purpose of presenting and explaining our services in a more customer-friendly and attractive manner.

Initially, no personal data is transmitted to YouTube as long as you do not watch the videos. 
If you watch the videos, personal data (IP address, browser data, terminal device data) will be transmitted to YouTube in the USA on the basis of your consent (within the meaning of Art. 6 para. 1 lit. a. GDPR). The plug-in informs Google that you as a user have visited this website. There is a possibility that your IP address will be stored. If you are logged into your Google account during your visit to this website, the aforementioned information will be linked to it.

You can find more information here: https://policies.google.com/privacy

Cookies

For information about the use of cookies, please visit the following:

Disclosure

Your personal data will not be transferred to third parties. However, data may exceptionally be transmitted for the following reasons:

  • insofar as you have given your explicit consent, Art. 6 para. 1 S. 1 lit. a GDPR
  • insofar as disclosure is required under Art. 6 para. 1 S. 1 letter f GDPR and there is no overriding interest worthy of protection in not disclosing your data
  • insofar as we are legally obliged to pass on the data, Art. 6 para. 1 S. 1 lit. c GDPR
  • in so far as disclosure is permissible and necessary in accordance with Art. 6 para. 1 S. 1 lit. b GDPR for the processing of contractual relationships with you
  • insofar as your data is processed by third parties commissioned by us, this is done based on Art. 28 GDPR by means of a contract processing agreement.

Transfer to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or do so in the context of using third-party services or disclosing or transferring data to third parties, this will only be done if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual authorizations, we only process data or have data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

A transmission of your data collected on this website takes place in the USA by Google, Freshworks, MailChimp and Zapier: By accepting further cookies, you consent according to Art. 49 para. 1 p. 1 lit. a GDPR to your data being processed in the USA by Google. By accepting newsletters or contacting us, you consent to your data being processed in the USA by Freshworks, MailChimp and Zapier in accordance with Art. 49 para. 1 sentence 1 lit. a GDPR.

Rights of data subjects

Right to inform Art. 15 GDPR

You have the right to ask us to confirm whether we are processing personal data from you. If this is the case, you can request information about this personal data and about the following information:

  • the purposes of processing
  • the categories of personal data processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or to international organizations
  • if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
  • the existence of a right to rectify or erase personal data concerning you or to limit processing or to object to such processing
  • the existence of a right of appeal to a supervisory authority
  • if the personal data is not collected from you, all available information about the origin of the data
  • the existence of automated decision-making, including profiling, in accordance with Art. 22 (1) and (4) DPA and, at least in these cases, meaningful information on the logic involved and the scope and intended effects of such processing on the data subject

Right of rectification Art. 16 GDPR

You can immediately request the correction of incorrect or complete personal data stored by us.

Right to deletion (right to be forgotten) of your data, Art. 17 GDPR

You can demand the deletion of your data stored with us, insofar as

  • the personal data are not relevant to the purposes for which they were collected or otherwise processed or are no longer necessary
  • you revoke your consent on which the processing is based pursuant to Art. 6 para. 1 S. 1 lit. a GDPR or Art. 9 para. 2 sentence 1 lit. a GDPR and there is consequently no other legal basis for the processing;
  • you lodge an objection to the processing pursuant to Art. 21 para. 1 GDPR and there are no legitimate reasons for the processing that take precedence or you lodge an objection to the processing pursuant to Art. 21 para. 2 GDPR;
  • the personal data were processed unlawfully;
  • the deletion of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which you are subject;
  • the personal data have been collected in relation to information society services offered in accordance with Art. 8, para. 1, GDPR.

Upon presentation of the prerequisites, we are obliged to delete the data unless the processing is necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.

Right to restrict processing, Art. 17 GDPR

You have the right to demand from us the restriction of the processing, insofar as

  • the accuracy of your personal data is disputed by you, but only for the time necessary to allow us to verify the accuracy of the data;
  • the processing is unlawful and you do not immediately wish your personal data to be deleted, but instead request that the use of your personal data be restricted;
  • we no longer need the personal data for the purposes of the processing, but you need the data to assert, exercise or defend legal claims; or
  • you have lodged an objection to the processing in accordance with Art. 21 Para. 1 GDPR, as long as it has not yet been established whether the legitimate reasons on our part outweigh the objection to you.

Insofar as processing is restricted, we may process your personal data - apart from storing them - only with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.

You will be informed again before the restriction is lifted.

Right to data transferability Art. 20 GDPR

You have the right to receive your personal data that you have provided us with in a structured, common, machine-readable format or to request that it be transferred to another responsible party.

Right of objection Art. 21 GDPR

You have the right to object, in accordance with Art. 21 GDPR, to the processing of your personal data if it is processed on the basis of a legitimate interest in accordance with Art. 6 para. 1 S. 1 letter f GDPR. However, this only applies if there are reasons arising from your particular situation or if the objection is directed against direct advertising.

Right of withdrawal Art. 7 para. 3 GDPR

You have the right to revoke your consent granted to us in accordance with Art. 6 para. 1 S. 1 lit. a GDPR at any time. This revocation applies exclusively to future use.You have the right to revoke your consent granted to us in accordance with Art. 6 para. 1 S. 1 lit. a GDPR at any time. This revocation applies exclusively to future use.

Right to appeal to supervisory authorities

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you are habitually resident, your place of employment or our registered office, if you consider that the processing of personal data relating to you is contrary to the basic data protection regulation.

Insofar as you wish to exercise your rights as a data subject, you can also submit a complaint by e-mail to the above-mentioned e-mail address.

Data security

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as requests that you send to us as site operator. You can recognize this by the fact that the address line of the browser changes from "http://" to "https://". In addition, a lock symbol can be seen in the browser line. 

If the SSL or TLS encryption is activated, the data that you transmit to us cannot be read by third parties.

We have also taken precautions in the form of technical and organizational measures to protect your data against accidental or deliberate manipulation, partial or complete loss, destruction or unauthorized access by third parties.

Topicality and amendment of this data protection declaration

This privacy policy is currently valid and has the status of June 2020.

In order to ensure that our data protection declaration always complies with the current legal requirements, we reserve the right to make changes at any time. This also applies if the data protection declaration has to be adapted due to new or revised services, for example new services. The new data protection declaration will then take effect on your next visit to our website.

Our data protection declaration is available on our website for you to view and print out at any time.

Complaints and admonition

Should you feel that your rights have been violated or you are otherwise disadvantaged, please inform us yourself. You will then receive a personal and individual reply. Within the scope of your duty to minimize damages, we would like to point out that costs incurred by a lawyer commissioned by you out of court, without prior contact, will not be borne by us. There is expressly no will on our part that you instruct a lawyer with a cease-and-desist letter and/or the submission of a declaration of discontinuance with the threat of prosecution. Consequently, a presumed intention cannot be considered.
Created with