As we want to protect your privacy, we make sure that your personal details are handled securely and confidentially. We are notifying you about our data protection regulations so that you know exactly what data we collect and forward where required.

A. Responsible data processing body

B. Data processing

C. Term of Data storage

D. Your rights as the affected party

A. Responsible data processing body

The responsible body for the processing of personal data within the scope of this website and in accordance with the provisions of the:

  1. Law Number 19 of 2016 Concerning The Information and The Electronic Transactions jo. The Minister of Communication and Information Regulation No. 20 of 2016 on Personal Data Protection in Electronic System (“Data Protection Regulation”); and
  2. Presidential Regulation Number 79 of 2019 concerning the Implementation of Electronic Systems and Transactions (“PR 79/2019”).

Berlitz Language Center

Gedung Central AIA, Level 31

Jl. Jend. Sudirman Kav. 48A, Jakarta Selatan

Tel.: +62 (813) 1691 6330

Website: www.berlitz.co.id

E-mail: info@berlitz.co.id

Our data protection officer is:

Steen Kirkby, email: info@berlitz.se[SS1]

In this data protection declaration, we would like to inform you about the extent to which your personal data (hereinafter referred to as "Data") is processed.

B. Data processing

We process Data for the operation of our website. The processing of this Data also includes the disclosure of the Data by transferring it to other companies.

The transfer of Data is governed by the laws and regulations in force in Indonesia.

The Data affected in such cases, the processing purposes, legal bases, recipients and transfers data are listed below:

  1. Log file

We record your visit to our webpages in a log file. In doing so, the following Data is processed: the name of each accessed webpage, the date and time of access, the data volume transferred, the browser type and version, the operating system used by you, the referrer URL (the previously visited website), your IP address and the access requesting provider. This is necessary in order to ensure website security. We process the Data accordingly on the basis of our legitimate interests pursuant to Data Protection Regulation. The log file will be deleted after the expiration of seven days, unless it is required for the clarification of or as evidence for specific infringements which have emerged during the retention period.

  1. Hosting

Within the scope of web hosting, all Data processed in connection with the operation of this website will be stored. This is necessary to ensure the operation of the website. We process the Data accordingly on the basis of our legitimate interests pursuant to Data Protection Regulation. We use the services of web hosting service providers, to whom we transfer the aforementioned data, for the operation of our website.

  1. How to contact us

When contacting us, your Data (name, contact details, to the extent provided by you) and your message will be used solely for the purpose of the processing and handling of your request. The Data will be used for the processing of your request on the basis of Art. 2 paragraph (2) Data Protection Regulation. For processing your contact requests, we work with service providers, to whom we transfer the aforementioned Data.

  1. Newsletter

In order to be able to regularly provide you with information on our company and our services, you can subscribe to our newsletter. When subscribing to our newsletter, we will process the Data entered by you (email address and other additional voluntarily provided data).

To do this, we require your consent, as follows:

“[ ] I would like to subscribe to the newsletter of Berlitz Language Center I can withdraw my consent at any time by sending an email to info@berlitz.co.id or by using the unsubscribe link provided in the newsletter.”

Based on your consent, our newsletter is then sent to you pursuant to Art. 2 paragraph (2) Data Protection Regulation upon registration. Subscriptions to our newsletter are subject to the “double-opt-in process”. In order to prevent abuse, we will send you an email upon receipt of your registration, requesting you to confirm your subscription. In order to be able to document the subscription process in accordance with the legal requirements, your subscription will be logged. Specifically, this means we will store the time of receipt of your registration and your subscription confirmation as well as your IP address. The newsletter is sent on our behalf by service providers, to whom we transfer the abovementioned data.

  1. Customer account

When opening a customer account, you automatically consent to the storage of your contact details (name, address, email address, bank details) and your usage data (user name and password). In doing so, we are able to identify you as a customer and you are able to manage your orders. In this context, we will obtain the following consent from you:

“[ ] I would like to create a customer account. Please save my data for this purpose. I can withdraw my consent at any time with reference to Art 20 Data Protection Regulation by sending an email to info@berlitz.co.id.”

Based on this consent, your Data will be processed pursuant to Art. 2 Paragraph (2) Data Protection Regulation and Art. 20 Data Protection Regulation.

  1. Purchase transaction

We process your order data for the fulfillment of the purchase contract. The Data is processed on the basis of Data Protection Regulation.

We will transfer your address data to the company assigned to dispatching the goods. Where required for the fulfillment of the contract, we will also forward your email address or your telephone number to agree a delivery date (advice note) with the dispatcher.

We will transfer your transaction data (name, order date, payment method, date of dispatch and/or receipt, payment amount and recipient, and, where applicable, bank details or credit card details) to the payment services provider entrusted with processing the payment.

  1. Appointment scheduling in the calendar

If you want to use our form for scheduling appointments, your Data (name, contact details, and selected language) will be used to process and handle your request. To provide this service, we work together with service providers, to whom we transfer the abovementioned data. The specified data is processed by us on the basis of Art. 2 Paragraph (2) Data Protection Regulation in order to execute your request.

  1. Prize draws

Your Data (name and contact details and company name and role in the event of participation on behalf of a company) must be disclosed if you want to take part in our Advent calendar prize draw. To process the prize draw, we work together with service providers, to whom we transfer the specified Data. The Data is processed on the basis of your consent given pursuant to Art. 2 Paragraph (2) Data Protection Regulation or on the basis of our legitimate interests in the marketing of our services pursuant to Data Protection Regulation.

  1. Career section

When contacting us in order to send us your job application, for example via our Softgarden platform, your Data (e.g. name, email address, preferred workplace, if provided), your message and the submitted application documents will be used solely for the purpose of processing and handling your job application request.

  1. Salesforce

For purposes of providing efficient customer support, we use the Salesforce customer management system. We use Salesforce to collect, link, and evaluate form data (contact details, customer account, order data, etc.) processed on our website. This data is transferred to Salesforce’s servers in the course of processing. Processing in this context is performed on the basis of our compelling interest in improving our customer service in accordance with Art. 2 Paragrpah 2 Data Protection Regulation. Salesforce is a cloud-based service. This means that services are provided via the Internet using servers that are distributed worldwide. Accordingly, it is possible that your data will be transferred to non-EU countries.

Salesforce ensures appropriate levels of data protection for transfers to third countries by means of binding corporate rules; in the case of transfers to the United States, this is accomplished through participation in the EU-US privacy shield, and through EU standard contract clauses.

Salesforce’s certification in the EU-US-Privacy-Shield can be found here:
https://www.privacyshield.gov/participant?id=a2zt0000000KzLyAAK&status=Active

Further information on data privacy can be found at:
https://www.salesforce.com/company/privacy/

  1. Website analysis and marketing

We use “cookies” to enable the use of certain functions. Cookies are small data packages which are installed on your device and exchanged with other service providers. Some of the cookies used by us will be deleted as soon as you close your browser (“session cookies”). Other cookies remain on your device and will enable us to identify your browser again on your next visit (“persistent cookies”).

You can delete all cookies saved on your device and adjust the settings of your browser to prevent the installation of cookies.

In this case, you may have to readjust some settings each time you visit our website and accept the impairment of some of the provided functions.

We use cookies in connection with the following functionality:

  1. Google Analytics

We use Google Analytics which is a service of Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043 USA. For the provision of its services, Google uses certain cookies. The information on your use of this website (including your IP address) generated by the cookies, is transferred to a Google server in the USA[YS7] , where they are stored. We use the stored information to analyze your use of our website, prepare reports on website activities for the website operator, and provide additional services in connection with the use of the website. We process the Data obtained with your consent pursuant to Art.2 paragraph 2 Data Protection Regulation. Under no circumstances will Google link your IP address to other Google data.

We would like to point out that this website uses Google Analytics with the "anonymizeIp()" expansion. This means that IP addresses are truncated prior to being transferred to the USA. Direct personal identification in connection with the saved Data is therefore generally not possible. Only in exceptional cases, will a complete IP address be transferred to a server in the USA and truncated there.

You can object to the collection of your Data at any time with future effect by applying the Google Analytics deactivation add-on for browsers at https://tools.google.com/dlpage/gaoptout?hl=en

Please also note the information on the use of data by Google available in the Google Partner network at: https://www.google.com/intl/de/policies/privacy/partners/

Google is certified at: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Additional information on data privacy is also available at: https://policies.google.com/privacy?hl=de&gl=de

  1. Facebook Remarketing/Retargeting: Facebook Custom Audiences (Pixel/Cookies)

We are using a so-called tracking pixel on our website, which means that a cookie will be saved on your device when you visit certain pages. These cookies will be permanently saved on your device. We use those cookies in order to understand which advertisements or third-party websites redirected users onto our website. That information is further utilized in order to optimize our website by analyzing the statistical data provided by the cookie. The data we receive is processed by us for the purposes of legitimate interest in the optimal marketing of our website content according to par.6 subpar 1 f) GDPR.

The cookies are not used for the personal identification of users. The data is anonymous and cannot be used to draw any conclusions about users’ identities. The information about your website usage gathered by this cookie (including your IP address) will be stored and processed by a Facebook server in the United States.

Facebook is certified:

https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

More information regarding your data protection can be found here:

https://www.facebook.com/help/568137493302217

You can revoke your consent to the collection and storage of data at any time with effect for the future by clicking this opt-out link.

  1. Fullstory

We use the FullStory analysis service, provided by FullStory Inc., 120 Ottley Dr NE Ste 100, Atlanta, GA 30324, USA (“FullStory”), to analyze user behavior on our website. FullStory records information about the behavior of website visitors, enabling us to analyze this behavior and to improve the user experience on our website. FullStory processes information such as clicks, mouse movements, input (with the exception of sensitive information), scroll movements, type of browser used, device type, IP address, pages visited, and session duration.

FullStory uses cookies to collect this information. The information generated by the cookie about your use of the website is transmitted to and stored by, FullStory on servers in the United States.

We process the data we receive when using FullStory in accordance with Art. 6(1)(f) GDPR on the basis of our compelling legitimate interest in the optimum marketing of our website.

You may object to data collection at any time with future effects by clicking the following opt-out link: https://www.fullstory.com/optout

FullStory is certified under: https://www.privacyshield.gov/participant?id&status=Active

You can find further information about FullStory’s Privacy Policy at:
https://www.fullstory.com/legal/privacy/

  1. AB Tasty

      To continually improve our online services, on our website, we use the service AB Tasty, Rosenstraße 2, 10178 Berlin, Germany (“AB Tasty”). AB Tasty uses cookies. This company processes statistical information about your visit to our website, the referrer URL, the device and browser you are using, your geolocation, language settings, number and location of clicks, and your IP address.

      The legal basis for this data processing is your consent pursuant to Article 6(1)(a) GDPR.

      You can withdraw your consent to this data processing at any time with effect for the future by customizing your preferences in our cookie settings. When using AB Tasty, personal data are transferred to third countries.

      p) Integration of third-party content

      We use dynamic content (“content”) from external sources to optimize the presentation of our website and what it offers. When visiting our website, an application programming interface automatically submits a request to the server of the respective content provider as part of which certain log data (e.g. the user’s IP address) is transmitted. The dynamic content is then transferred to our website and displayed there.

      We use external content in connection with the following features:

      aa) Integration of YouTube videos

      We have integrated videos from YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, United States (“YouTube”) on our website. The controller for YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”). However, when you play the videos, log data will be transferred to YouTube’s servers in the United States. Processing in this manner is performed on the basis of our overriding legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR.

      The European Commission has not issued an adequacy decision for transfers of data to the United States. Google ensures adequate levels of data protection via the EU standard contractual clauses. A link to the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.

      bb) Google Maps

      We use Google’s Google Maps service on our website in order to provide you interactive maps. When the map is displayed, data, including your IP address and your location, is transferred to Google’s servers and stored there. Processing in this manner is performed on the basis of our overriding legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR. The controller for Maps is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”). It cannot be ruled out that data may be transferred to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States.

      The European Commission has not issued an adequacy decision for transfers of data to the United States. Google ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clause will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.


      C. Term of Data storage

      We will only store Personal Data for as long as is required for the purpose for which it is processed or until you withdraw your consent to the processing of such Data. Where statutory retention obligations must be complied with, the storage period for certain Data may be up to 10 years, regardless of the processing purposes.

      D. Your rights as the affected party

      1. Right to information

      On request, we will provide you with information on the personal Data stored on you, at any time and free of charge.

      1. Correction, deletion processing restrictions (blocking), objection

      If you no longer consent to the storage of your personal Data or if your Personal Data is no longer accurate, we will initiate the deletion[YS9] or blocking of your Data at your request or ensure that your Data is updated accordingly (to the extent possible in accordance with the applicable laws and regulations). The same applies if you want your Data only to be processed subject to certain restrictions in the future.

      1. Data portability

      On request, we will provide you with your Data in a common, structured and machine-readable format so that you can transfer the Data to another competent party, where required.

      1. Right of appeal

      You have a right of appeal to your competent authority:

      1. Right to withdraw consent with future effect

      You can withdraw your given consent at any time with future effect. The withdrawal of your consent will, however, in no way affect the lawfulness of the processing of your Data before the time of withdrawal.

      1. Restrictions

      Data that cannot be used to identify the affected party, for example, which has been anonymized for analysis purposes, are not affected by the above rights. The provision of information, deletion, blocking, correction or transfer of Data to another company may be possible if you provide us with additional information which enables identification by us.

      1. Exercise of your rights as an affected party

      If you have any questions regarding your Personal Data, the provision of information, corrections, blocking, objections or the deletion of Data or want your Data to be transferred to another company, please contact info@berlitz.co.id.