Data protection is of a particularly high priority for us. The use of our Internet pages is possible without any indication of personal data; however, if you want to use special services via our website or contribute any kind of content, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from you.
The processing of personal data, such as the name, address, e-mail address, or telephone number shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations of Germany. By means of this data protection declaration, we would like to inform you of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, we inform you about the rights to which you are entitled.
As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
This summary does not substitute the regular data privacy statements below. It should give you a quick overview of the use of personal data on this website.
- To analyze website usage and visitor behavior, we use Google Analytics with anonymized IP-addresses.
- You can sign up for our email newsletter. We use a third party newsletter solution called MailerLite.
- Any personal data you intentionally provide us will only be used for the intended purpose, e.g. providing you with the requested information, fulfilling a contract or delivering special services to you.
This data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable to the general public, as well as our customers and business partners. To ensure this, we would like first to explain the terminology used.
In this data protection declaration, we use, among other things, the following terms:
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other bodies which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
The processor is a natural or legal person, public authority, agency or other bodies which processes personal data on behalf of the controller.
The recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
The third party is a natural or legal person, public authority, agency or body other than you, the controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of you is any freely given, specific, informed and unambiguous indication of your wishes, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to you.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is (in this text also referred to as “we, us, our,…”):
Larissa Christin Schreyer
Email: [email protected]
You may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
4. Collection of general data and information
This website collects a series of general data and information when you visit the website. This general data and information are stored in the server log files. Data collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, we do not draw any conclusions about you. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, we analyze anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application, the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
6. Registration on our website
You have the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by you are collected and stored exclusively for our internal use, and for our own purposes. We may request the transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to us, the controller.
By registering on our the website, the IP address — assigned by the Internet service provider (ISP) and used by you — date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure us. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
Your registration, with the voluntary indication of personal data, is intended to enable us to offer contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock.
We, at any time, provide information upon request to you as to what personal data are stored about you. In addition, we correct or erase personal data at your request or indication, insofar as there are no statutory storage obligations. The entirety of our employees is available to you in this respect as contact persons.
7. Email Newsletter
On this website, you are given the opportunity to subscribe to our newsletter. You only need to submit your email address to subscribe.
We inform you regularly by means of an email newsletter about the latest news in TEFL industry and special offers. The newsletter may only be received by the data subject if you have a valid e-mail address and you register for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether you as the owner of the e-mail address are authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by you at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address at a later date, and it, therefore, serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances.
The subscription to our newsletter may be terminated by you at any time. The consent to the storage of personal data, which you have given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time by sending us an email or a message via our contact forms on this website.
8. Contact possibilities on this website
If you contact us by e-mail or via a contact form on this website, the transmitted personal data are automatically stored. We only store and use the submitted personal for the purpose of your inquiry, e.g. to provide you with further information or deliver special services to you.
There is no transfer of this personal data to third parties unless it is explicitly differently stated. If a service is delivered by one of our partners, we ask for your explicit consent to share your data with the respective partner.
9. Comments function in the blog on the website
You can leave individual comments on blog posts on this website. You have to submit at least your email address and a “username” (pseudonym) to leave a comment, the indication of your website is optional.
If you leave a comment, the comment and your submitted data are stored, as well as information on the date of the commentary and the IP address assigned by the Internet service provider (ISP) to you. This storage of the IP address takes place for security reasons, and in case you violate the rights of third parties or post illegal content through a given comment. The storage of these personal data is, therefore, in our own interest, so that we can exculpate in the event of an infringement. This collected personal data will not be passed to third parties unless such a transfer is required by law or serves the aim of the defense of the data controller.
10. Routine erasure and blocking of personal data
We process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which we are subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
11. Your individual rights
All of the below-mentioned rights are granted by the European legislator. If you wish to avail yourself of any of the given rights, you may, at any time, contact any employee of the controller. An employee will arrange the necessary measures in individual cases.
Right of confirmation
You have the right to obtain our confirmation as to whether or not personal data concerning you are being processed by us.
Right of access
You have the right to obtain free information from us about your personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant you access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, you have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, you have the right to be informed of the appropriate safeguards relating to the transfer.
Right to rectification
You have the right to obtain without undue delay the rectification of inaccurate personal data from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (Right to be forgotten)
You have the right to obtain the erasure of personal data concerning you without undue delay from us, and we have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- You withdraw consent to which the processing is based according to the point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing or you object to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
Where we have made personal data public and are obliged pursuant to Article 17(1) to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you have requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.
The right of restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data.
- The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead.
- We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims.
- You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of us override those of you.
Right to data portability
You have the right to receive from us the personal data concerning you, which was provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
Right to object
You have the right on grounds relating to your particular situation, at any time, to object to the processing of personal data, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to the profiling based on these provisions.
We no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of you, or for the establishment, exercise or defense of legal claims.
If we process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing. This applies to the profiling to the extent that it is related to such direct marketing. If you object to the processing for direct marketing purposes, the Larissa Christin Schreyer will no longer process the personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.
Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between you and us, or (2) is not authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between you and us, or (2) it is based on your explicit consent, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on our the part, to express your point of view and contest the decision.
Right to withdraw data protection consent
You have the right to withdraw your consent to processing of your personal data at any time.
12. Use of Facebook components
On this website, we have integrated components of the social network Facebook.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect your privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by you to prevent a data transmission to Facebook.
13. Use of Google AdSense components
On this website, we have integrated Google AdSense. Google AdSense is an online service which allows the placement of advertising on third-party sites. Google AdSense is based on an algorithm that selects advertisements displayed on third-party sites to match with the content of the respective third-party site. Google AdSense allows an interest-based targeting of the Internet user, which is implemented by means of generating individual user profiles.
The operating company of Google’s AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google’s AdSense component is the integration of advertisements on our website. Google AdSense places a cookie on your information technology system. The definition of cookies is explained above. With the setting of the cookie, Alphabet Inc. is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google AdSense component is integrated, your Internet browser on the information technology system will automatically submit data through the Google AdSense component for the purpose of online advertising and the settlement of commissions to Alphabet Inc. During the course of this technical procedure, the enterprise Alphabet Inc. gains knowledge of personal data, such as the IP address, which serves Alphabet Inc., inter alia, to understand the origin of visitors and clicks and subsequently create commission settlements.
You may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Alphabet Inc. from setting a cookie on your information technology system. Additionally, cookies already in use by Alphabet Inc. may be deleted at any time via a web browser or other software programs.
Furthermore, Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in web pages to enable a log file recording and a log file analysis through which a statistical analysis may be performed. Based on the embedded tracking pixels, Alphabet Inc. is able to determine if and when a website was opened by you, and which links were clicked on. Tracking pixels serve, inter alia, to analyze the flow of visitors on a website.
Through Google AdSense, personal data and information—which also includes the IP address, and is necessary for the collection and accounting of the displayed advertisements—is transmitted to Alphabet Inc. in the United States of America. These personal data will be stored and processed in the United States of America. The Alphabet Inc. may disclose the collected personal data through this technical procedure to third parties.
You can opt out of Google’s personalized advertising by visiting https://www.google.com/settings/ads.
14. Application of Pinterest components
On this website, we have integrated components of the social network Pinterest.
The operating company of Pinterest is Pinterest Inc., 808 Brannan Street, San Francisco, CA 94103, UNITED STATES.
The data protection guideline published by Pinterest, which is available under https://about.pinterest.com/privacy-policy/, provides information on the collection, processing and use of personal data by Pinterest.
15. Application of Twitter components
On this website, we have integrated components of the social network Twitter.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.
The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy/.
16. Application of YouTube components
On this website, we have integrated components of the online video platform YouTube.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
17. Application of Shariff components
On this website, we have integrated the component of Shariff. The Shariff component provides social media buttons that are compliant with data protection. Shariff was developed for the German computer magazine c’t and is published by GitHub, Inc.
The developer of the component is GitHub, Inc. 88 Colin P. Kelly Junior Street, San Francisco, CA 94107, United States.
Typically, the button solutions provided by the social networks already transmit personal data to the respective social network, when a user visits a website in which a social media button was integrated. By using the Shariff component, personal data is only transferred to social networks, when the visitor actively activates one of the social media buttons.
Further information on the Shariff component may be found in the computer magazine c’t under http://www.heise.de/newsticker/meldung/Datenschutz-und-Social-Media-Der-ct-Shariff-ist-im-Usatz-2470103.Html provided. The use of the Shariff component is intended to protect the personal data of the visitors of our website and to enable us to integrate a button solution for social networks on this website.
Further information and the applicable data protection provisions of GitHub are retrievable under https://help.github.com/articles/github-privacy-policy/.
18. The legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect your vital interests or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third parties. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed you are a client of us (Recital 47 Sentence 2 GDPR).
19. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
20. The period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
21. Provision of personal data as a statutory or contractual requirement
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner).
Sometimes it may be necessary to conclude a contract that you provide us with personal data, which must subsequently be processed by us. You are, for example, obliged to provide us with personal data when our company signs a contract with you. The non-provision of the personal data would have the consequence that the contract could not be concluded.
Before you provide personal data, you must contact any employee. The employee clarifies to you whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
22. The existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.