## General information on the processing of personal data relating to your studies with us

In the context of your studies at IU Internationale Hochschule GmbH (hereafter IU), IU is required to process data concerning your person. The purpose of this document is to inform you about our processing of your personal data when you enrol with and study at IU. If you are entering into a student employment contract with IU, you will receive separate information concerning the data processing involved. You can find details concerning the processing of personal data in connection with the use of our website in the privacy policy for the site, which is available online. Data processing using online tools will be explained to you for the tools in question.

### Privacy notice

0 PRIVACY NOTICE
0.1 Data Protection Information for Websites
​​​This Privacy Notice explains how your personal data is processed in connection with the use of this website and the provided functionalities, such as the menu for ordering information, a blog and search functions (hereinafter collectively referred to as the „Website“), and other processing operations described below.
This Website uses SSL or TLS encryption for security and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries submitted to the data controller). You can recognize an encrypted connection by the string “https://” and the lock symbol in your browser line.
0.2 Data Protection Information for Use of Safe (IU File Sharing Portal)
This Privacy Notice explains how your personal data is processed in connection with the use of Safe, IU’s portal for file sharing (hereinafter referred to as „Website“).
This Website uses SSL or TLS encryption for security and to protect the transmission of personal data and other confidential content. You can recognize an encrypted connection by the string “https://” and the lock symbol in your browser line.

### 1. Data controller and data protection officer

This Website is operated by IU Group N.V., Square Ambiorix 10, BE-1000 Bruxelles („IU Group“). IU Group is the data controller for the processing of your personal data.

IU Group processes your personal data on a subject-related basis in joint controllership with other companies belonging to the Group (all with their registered office at Mülheimer Straße 38, 53604 Bad Honnef, Germany, unless otherwise stated). Activities in connection with the operation of the IU International University are carried out in joint controllership with IU Internationale Hochschule GmbH, Juri-Gagarin-Ring 152, 99084 Erfurt ("IU"), also with regard to its study programs including getting into contact and the provision of information; if you are enrolled in or interested in a medical or psychological study program, processing is executed in addition in joint controllership with IU Health University GmbH, Große Bleiche 14-20, 55116 Mainz ("IU Health"). For central services within the Group, such as controlling, accounting and personnel administration, office, process and quality management, purchasing and sales, as well as other services, the aforementioned companies receive support of IU Corporate Services GmbH, which is jointly responsible for data processing; IU IT Services GmbH, Ridlerstr. 57, c/o IU Group NV, 80339 Munich, with regard to the provision of the operational IT infrastructure including hardware and software, telecommunication and electronic communication; IU Examination Service GmbH for services in the field of examination supervision; IU Marketing Service GmbH as well as IU Sales Services GmbH, Ridlerstr. 57, c/o IU Group NV, 80339 Munich, for services in the area of marketing and sales (this also includes marketing via this website and the operation of the applicant portal for students); IU Commercial 1 GmbH for the management of the online campus and IU Commercial 2 GmbH for the management of the campus locations and with regard to the campus programs; IU Student Services GmbH together with the respective GmbH that exists for the respective location and is named after its city name, e.g. IU Dortmund GmbH or IU Bonn GmbH, for the support of prospective students and students, in particular student advising. We can provide you with excerpts from the joint controller agreement. If you would like to receive an excerpt, please contact datenschutz@iu.org.

IU Group has appointed Dr. Annette Demmel, SPB DPO Services GmbH, An der Buche 4, 13465 Berlin, annette.demmel@spb-dpo-services.com, as the data protection officer for the aforementioned companies. You can contact IU Group either in writing or per email at datenschutz@iu.org.

Recipients

Unless otherwise described in the context of a certain processing, only those IU employees, who are responsible for performing a specific task have access to your personal data. In addition, employees who are responsible for operating our IT systems may have access to some of your personal data as part of their job, e.g., administering an application or performing IT security control tasks. Our employees are obligated to maintain the confidentiality of all personal data.

In the course of our business activities, we rely on the support of various service providers, in particular for the aforementioned purposes as well as for the operation of our IT systems. If the service providers we use have access to personal data, we have entered into the necessary agreements to protect your personal data; in particular, we have concluded data processing agreements in accordance with Art. 28 GDPR, in which we oblige our service providers to maintain confidentiality. Furthermore, banks may receive personal data for the purpose of processing payments, or lawyers, tax advisors and auditors may receive personal data in the course of their work for us. In some cases, we transmit personal data due to legal obligations. In the event of a suspected criminal offense or during investigative proceedings, data may be transmitted to the police and public prosecutor’s office. For further information about who has access to your personal data when using the individual applications, please refer to the description of the respective application.

Transfers to Third Countries

If we transfer data to service providers in so-called third countries, this is described for the respective application. Some of these third countries do not have an adequate level of data protection. Particularly in the case of data transfers to the USA, there is a risk that your personal data will be processed by the authorities there for control and monitoring purposes without you becoming aware of this or having sufficient legal remedies available to you. We routinely safeguard transfers to third countries by using the so-called EU standard contractual clauses. You can obtain a copy of these clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=de
.

Consent

If you have given your consent to a processing activity, you may withdraw this consent at any time with effect for the future without providing a reason. For this purpose, please use the methods for contacting IU mentioned above or change the switch settings if you have given your consent via the selected switch settings.

Retention

It is our general policy to delete your data as soon as it is no longer needed for the required purpose and if there are no retention obligations. We usually delete your personal data within a short period of time, e.g. within a few months after the conclusion of any counseling. Unless special circumstances regarding deletion are described for the respective application, we process your personal data in accordance with the various retention periods under university or federal law for up to 15 years or in accordance with retention periods under tax and commercial law for a period of six to ten calendar years after the conclusion of a transaction or after the end of the contract. If you object to any processing under Art. 21 (2) GDPR, we will delete your data within four weeks after your objection, unless otherwise required by law or if we are obligated to block the data. If the processing takes place on the basis of your consent and you withdraw your consent or the processing ends for other reasons, we will process the information necessary to prove that consent had previously been granted, i.e. date, time, details of the granting and subject of the consent, for a period of three years after the processing based on consent ends.

### 2. Data collection when visiting the website

When using our Website for informational purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called „Server Log Files“). When you access our Website, we collect the following data, which is technically necessary in order to display the Website for you:

- Our Website visited

- Date and time of access

- Quantity of data transmitted in byte

- Source/reference from which you reached the page

- Browser used

- Operating system used

- IP address used

The processing takes place in accordance with Art.6(1)(b) of the General Data Protection Regulation (“GDPR”) on the basis of your use of our Website and our interest in improving the stability and functionality of our Website in accordance with Art.6(1)(f) GDPR.

We process your data in order to provide you with a functional website, retain the data for the duration specified by IU for this purpose and delete your data thereafter.

Only employees of IU who are responsible for maintaining the Website receive access to your personal data.

We use third-party services on our Website. Further information about these services and the related data processing is found in this Privacy Policy or the cookie settings
.

### 3. Cookies

Depending on your browser settings and whether you have given us your consent, cookies may be used when you visit this Website in order to extend the functionality of the Website and make it more convenient for you to use. Cookies are small text files that are stored on your computer. Most of the cookies used by IU are deleted from your hard drive at the end of the browser session („Session Cookies”). In addition, IU uses so-called permanent cookies („Persistent Cookies”), which remain on your device in order to recognize you the next time you visit the Website. If cookies are used, they collect and process to an individual extent certain user information such as browser and location data, IP address values and as described in the Server Log Files. Persistent cookies are automatically deleted after a specified period of time, which may differ depending on the cookie.

An overview of the cookies used and the duration of the respective cookie storage can be found in the cookie settings in our Cookie Consent Tool
.

If personal data is also processed through individual cookies used by us, the processing takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our Website (so-called „Necessary Cookies”) or in accordance with Art. 6(1)(a) GDPR on the basis of your consent for all other cookies (marketing and analysis cookies).

Please note that you can configure your browser in such a way that you are informed about the use of cookies and can decide individually whether to accept or to refuse to accept them in certain cases or in general. Each browser differs in the way it manages cookie settings. Cookie settings are described in the help menu of each browser, which explains how you can change your cookie settings.

Please note that if you do not accept cookies, the functionality of our Website may be limited.

### 4. Cookie Consent Tool

This website uses a so-called cookie consent tool of Usercentrics GmbH, Rosental 4, 80331 Munich, Germany (the „Cookie Consent Tool“) to obtain consent to the use of cookies and cookie-based applications that require consent.

By integrating a corresponding JavaScript code, users are shown a banner when they access our Website, in which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.

The Cookie Consent Tool blocks the use of all cookies requiring consent until the respective user grants the corresponding consent by ticking the appropriate box. This ensures that cookies of this type are only placed on the user’s device if consent has been granted.

In order for the Cookie Consent Tool to be able to clearly assign page views to individual users and to individually record, log and store the consent settings chosen by the user for a session duration, certain user information, as described in the Server Log Files and including the IP address, is collected by the Cookie Consent Tool when our Website is accessed, transmitted to servers of the Cookie Consent Tool and stored there. For further details, please refer to the information provided in each case in the Cookie Consent Tool.

The data processing carried out by the Cookie Consent Tool takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in a legally compliant, user-specific and user-friendly consent management for cookies and thus our legitimate interest in our Website being lawfully designed.

We have concluded a data processing agreement with Usercentrics GmbH, which obligates Usercentrics GmbH to protect the data of visitors to our Website and to refrain from disclosing such data to third parties.

We process your data for this purpose for the duration of your session and delete your data thereafter, unless you have given your consent to the use of cookies, in which case we process your data for the duration specified for each cookie.

For further information on the use of data by Usercentrics GmbH, please refer to Usercentrics’ Privacy Policy at https://usercentrics.com/privacy-policy/
.

### 5. Contact (e.g. by email)

If you contact us by e-mail, we process the information necessary to answer your contact requrest, e.g. your e-mail address, the information you provide and the date and time of the contact. If you also provide us with your name and other personal data, we also process these.

If you conduct an online meeting with us or request consultation with regard to the studies, we additionally process your name displayed, if applicable your profile picture, preferred language, date, time, meeting ID, if applicable your phone number, as well as exchanged texts, audio and video data. To handle our communications, we use Microsoft 365, Microsoft Teams, both services are provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft") and Zoom Video Communications, Inc., 55 Almaden Boulevard, Suite 600, San Jose, CA 95113, USA („Zoom“).

The legal basis for this processing is Art. 6 (1)(b) GDPR or Art. 6 (1)(a) GDPR for such information that is not absolutely necessary for the meeting and that you provide to us voluntarily. We process your data in order to respond to your inquiry or conduct a consultation. Your personal data will be retained in each case for the period determined by IU in order to perform the task and will be deleted thereafter. This is based on the retention periods under commercial and tax law. Only employees of IU who are responsible for responding to contact requests will receive access to your personal data.

We have concluded data processing agreements with Microsoft and Zoom based on the EU Standard Contractual Clauses. You can access the EU Standard Contractual Clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en
. For more information on data processing by Microsoft, please visit https://privacy.microsoft.com/de-de/privacystatement
and for Zoom https://explore.zoom.us/en/privacy/
.

#### 5.1 WhatsApp

​​If you decide to communicate with us via WhatsApp as part of your application for admission or during your studies, we will process your personal data, such as your telephone number, your picture, your status information and your name if you provide us with this information. In addition, we process any personal data that you communicate to us via WhatsApp. In this regard, we recommend that you only provide us with the information that is absolutely necessary to answer your request and refrain from providing any additional information. Whether you use WhatsApp is up to you, and you can receive the same information by phone, electronically and/or regular mail.

We use a ChatBot based on artificial intelligence in our WhatsApp channel. The functionality and data processing of this is described in the following section. You are free to decide whether you use WhatsApp and you can receive the same information by telephone, electronically and/or by post.

IU processes your personal data in order to communicate with you. The legal basis for this data processing by IU is your use of our WhatsApp channels in accordance with Art. 6(1)(b) GDPR.

You can withdraw your consent to the processing of your personal data at any time. The withdrawal can be made via the specified contact options. The declaration of withdrawal does not affect the lawfulness of the processing carried out so far.

The data processing by WhatsApp is governed by the Privacy Policy of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, which can be found at https://www.whatsapp.com/legal/?lg=de&lc=DE&eea=1#privacy-policy
.

WhatsApp is a telecommunications service offered by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and a company of Facebook Inc.

Access to your personal data is granted to those IU employees who manage our WhatsApp channels. IU uses a software solution of the provider Messenger People, which does not require an app installation. Even if the use of the software solution largely excludes access to data by WhatsApp, it cannot be ruled out that employees of WhatsApp or Facebook may also receive access to your personal data. Likewise, it cannot be ruled out that your data will be stored on WhatsApp servers in the United States of America. For this purpose, a contract that incorporates the EU standard contractual clauses has been concluded. You can find further information in this regard in WhatsApp’s Privacy Policy, if applicable. Your personal data will be retained in each case for the period determined by IU in order to perform the task and then deleted.

#### 5.2 Unibuddy

​IU uses a live chat provided by Unibuddy Ltd, Third Floor, 20 Old Bailey, London EC4M 7AN, United Kingdom ("Unibuddy"). The live chat is conducted by students or other individuals who can provide information on the topics requested. To use Unibuddy, you are required to create an account with Unibuddy in accordance with Unibuddy's terms of use and privacy policy. When using Unibuddy, IU processes your name, email address, phone number (if you provide it), and the time of your request in its Salesforce CRM system, provided by Salesfore, Floor 26, Salesforce Tower, 110 Bishopsgate EC2N 4AY London, United Kingdom, and in this way can determine whether you have previously made an inquiry to IU and whether and when your inquiry was answered. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a) GDPR. You can withdraw your consent at any time by addressing to the specified contact options. The withdrawal does not affect the lawfulness of the processing that has taken place to date.

​Access to your personal data will be granted to those IU employees who are in charge of the live chat via Unibuddy. When transferring your data from Unibuddy to our CRM system, it may be stored in the United States of America. For this purpose, a contract has been concluded that includes the EU Standard Contractual Clauses. In each case, your personal data will be stored for the period of time determined by the IU with regard to the performance of the task and then deleted. For more information on data processing by Unibuddy, please refer to Unibuddy's privacy policy, which can be found at https://unibuddy.com/privacy-policy/
.

5.3 AI based Chat bot Syntea

Syntea is your 24/7 learning support. Syntea stands for Synthetic Teaching Services. You can use Syntea, for example, to answer question while you study or to assess gaps in your knowledge. Your usage history is saved so that you can access it for a year. Other students cannot see which questions you ask and have no insight into your usage history. In order to improve Syntea’s ability to assist all students, your questions are made available to other users without personal reference, i.e. after deletion of your name and other identifying information with the corresponding answers. The questions and answers are checked by a teacher beforehand to ensure that they are correct. Neither the other students nor the teachers can see who asked the question. Likewise, when receiving answers to your questions, you cannot see who contributed to the selected questions and answers. This increases the knowledge base of Syntea and improves the services ability to assist in situations where many students need support. Syntea is based on artificial intelligence.

In order to use Syntea, you must consent to the processing of your data. Your consent relates to your personalized usage history ("My Area") as well as the removal of your personal data from your questions and usage to make it available for others to use ("Pool"). Syntea places a cookie; please see here for further information.

My Area. In order to provide you with personalized use so that you can use, save and retrieve study aids tailored to you, as well as save questions and answers in your area, we process your name, email address, details of the courses in which you are enrolled, your study location and your device ID (browser information) (hereinafter collectively "User Data"). This information is shared with Syntea by the website where it appears and stored to make our services more usable for you. In addition, we process the following data that is generated during your use of Syntea: Your text-based interactions with Syntea, questions you formulate, commands issued to Syntea, non-functional dialogue, a selection of answers based on your questions, the results of the answer selection, partially completed assessment answers, the time of interactions, links to external sources, course books, user settings, display settings, sound settings (hereinafter collectively "Usage Data").

Pool. In order to prepare questions for the corresponding courses in the best possible way, your course affiliation and your usage history are analyzed and the findings are used to improve the services we offer. For this purpose, your user data will be deleted and replaced by a user code. Neither other students nor teachers can see which questions you have asked or how you have used Syntea. The user code is only visible to the employees who are responsible for the operation of Syntea. For Syntea we use software that tries to predict which question will be asked next by evaluating previous questions and knowledge levels and makes these findings available to all users, e.g. in the form of selected quiz questions. The knowledge base and accuracy of success of Syntea is increased enormously in this way, because all students benefit from the Syntea usage of other students.

The legal basis for data processing is your consent pursuant to Art. 6 par. 1 a) General Data Protection Regulation. You can revoke your consent at any time with effect for the future by sending us a corresponding message, e.g. by email to datenschutz@iu.org.

Only you and selected employees of the IU, who are responsible for the operation of Syntea, have access to your user data and usage data in "My Area". As far as teachers review questions and answers for their professional correctness and appropriateness, they do not receive any personal data that identifies you as a person. All Syntea users have access to the questions and answers in the pool. The user code, which with additional information from other sources could enable an identification of your person, is only accessible to employees of the IU who are responsible for the operation of Syntea.

In addition, IU employs internal and external IT staff to maintain the IT systems, who may have access to your personal data in the course of their work.

Your hashed user ID and your question will be transmitted to OpenAI, L.L.C., 3180 18th Street, San Francisco, CA 94110, USA. This transfer of your personal data is based on EU standard contractual clauses. A copy of the EU Standard Contractual Clauses can be found here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj
. Please note that countries outside the EU may have a lower level of data protection than the EU and may not have sufficient legal protection against access to data by government authorities. For additional information

Syntea is hosted on servers operated by Amazon Web Services EMEA Sàrl, 38, avenue John F. Kennedy, L-1855 Luxembourg ("AWS") in the EU. In exceptional cases, AWS may transfer personal data outside the EU to Amazon Web Services, Inc. in the US. This transfer is based on the Data Privacy Framework: https://www.dataprivacyframework.gov/s/program-overview
.

We store personal data for one year and then delete it.

### 6. Online information events

If you register to participate in an online information event via our Website, then we process your first and last name and your email address in addition to the data mentioned under Server Log Files. We process your data on the basis of Art. 6(1)(b) GDPR in order to send you an invitation to our online information event. Your personal data will be retained in each case for the period determined by IU in order to perform the task and then deleted. You will receive information on the processing of your data by the provider of the video conferencing tool when you receive the invitation.

We will store information about your completed registration in your browser and, by using a cookie, information in the fields you populated subject to your consent, so that you can use the pre-filled fields when you register again and you will be shown for which event you are already registered. We process your data on basis of Art. 6 (1) (a) GDPR. You can withdraw your consent for the local storage in the browser and the processing of your data for the purpose of pre-filling the fields separately at any time with future effect. You can declare your withdrawal by using the cookie consent tool and declare it by emailing datenschutz@iu.org.

### 7. Request for free info brochure

If you request information material to be sent to you electronically, we will process your title, first and last name, email address, telephone number (if applicable) and details of the subject of the requested information in order to provide you with the information material. The legal basis for this processing is Art. 6(1)(b) GDPR. If we do not reach you by email and you have provided us with your consent in accordance with Art. 6(1)(a) GDPR, we will contact you by telephone. Access to your data will be granted to those employees who are responsible for managing and processing such requests as part of their job.

To collect your personal data described above, we use Google Lead Form Ads, an application provided by Google Ireland Ltd. ("Google"), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. The information you enter in the form to request information material may be transferred to a Google server in the US. The data entered in the form is encrypted and stored by Google for up to 60 days. Only the IU has access to this data. To secure this data transfer, the IU has entered into a data processing agreement with Google, which includes EU Standard Contractual Clauses. You can access the EU Standard Contractual Clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en
.

### 8. Enrollment for studies

8.1 Einrollment via Website
If you register for a course of study via the website, we process your name, date of birth, nationality, address, contact information (including, for example, your phone number), details of your previous education in the form of certificates, letters of recommendation, and a resume, your desired field of study, and payment details such as account information, as well as data for the preparation and execution of the education contract concluded with you.
Please note that when uploading a copy of your official ID document, you must redact all fields except your last name, first name, date of birth and nationality as well as the photo and the validity of your ID.
We require additional information to check whether you are eligible to study and whether there are any obstacles to enrolment, e.g. parallel enrolment at another university in the same degree program. Any further information you provide, e.g. in a CV, which is not mandatory for checking your university entrance qualification, is voluntary. However, if you, for example, wish to have ECTS points transferred and credited it is advantageous to provide information on previous stages in your education. We will process the additional information in your CV in order to draw your attention to the possibility of crediting previous educational achievements as part of your studies and to advise you on your choice of studies. If you have obtained your university entrance qualification through a high school diploma (German Abitur), we do not necessarily need information on your professional experience. If you have completed vocational training or a course of study in a subject that has no connection or overlap with the desired course of study, we do not require any information in this respect either. However, please bear in mind that our academic advisors have specialized knowledge regarding possible credits that you may not consider but could nevertheless be beneficial to you. We use artificial intelligence to initially review application documents. Further information can be found in the following section.
We process the data required for the examination of the university entrance qualification on the basis of Art. 6 (1)(c) GDPR in conjunction with sec. 70 par. 1 Thuringian Higher Education Act and the General Admission and Enrolment Regulations of the IU (AZE). We process information that is also required for the conclusion of the study contract, e.g. your bank account details, in order to prepare the conclusion and execution of the study contract in accordance with Art. 6 (1)(b) GDPR. We process any further voluntary information you provide for the purpose of receiving advice on the basis of your consent in accordance with Art. 6 (1)(a) GDPR. You can withdraw your consent to the processing of voluntary information at any time with future effect. Please use the IU contact channels mentioned at the beginning.
If you decide to cache your online application and complete it at a later date, we will send you a link to the storage location to your email address where we will retain the incomplete application for you for 30 days to access for completion. If you wish to receive a study contract by postal mail, we will use your data to summarize the information you have provided so far in a draft and send it to you by postal mail.
If you fill out the online application for recognition/credit for previous achievements via the Website, we collect your contact data, including name and postal address, email address, your telephone number, desired course of study, information on your previous education and your previous professional career, information on other qualifications, evaluations, training and work references.
The legal basis in this regard is Art. 6(1)(b) GDPR. You will receive detailed information on the processing of your personal data during the registration and recognition process. Access to your personal data is granted to those employees who are responsible for supporting applicants in the Enrollment Office or the Admissions Office of IU.
We process the phone number you provide for conducting multi-factor authentication as part of your logins to our systems. This is to ensure adequate security measures are in place according to the current state of technology, aimed at preventing unauthorized access to our systems, your user accounts with us, and ultimately your data. As part of multi-factor authentication, you may receive a code via SMS to your phone number when logging into our system, which you can then enter in the login area to verify that it is a legitimate access request. The processing is carried out pursuant to Art. 6(1)(f) GDPR to safeguard our legitimate interest in the secure operation of our systems. We utilize the services of external IT providers to maintain the multi-factor authentication system. Where these providers have access to personal data, we have made the necessary agreements to protect your personal data. If data is transferred to so-called third countries, we have concluded the EU Standard Contractual Clauses (you can retrieve a copy at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en
) or the EU-US Data Privacy Framework applies (https://www.dataprivacyframework.gov/s/program-overview
).
Personal data that you provide in the course of enrolling for a course of study will be retained for the duration of your studies and in accordance with statutory retention periods (for a period of six to ten years under the German Fiscal Code and the German Commercial Code). Data collected in the context of an application for possible recognition/credit of prior achievements will be stored for twelve months from the date of submission of the application. If matriculation does not take place during this period, the application together with all documents will be deleted.
For further information, please refer to the privacy notice for students, which you will receive with the documents to enroll in a degree program.
8.2 Visa data of international students
As part of our application process and student administration, we process visa data for international applicants and students. Visa data is processed to verify the authenticity and validity of the visa submitted in preparation for the conclusion of the contract and enrollment, as well as to execute the study relationship (e.g., clarification of study-related attendance options). Applicants for study programs are required to present a valid visa as part of the admission and enrollment process. Without this information, the study contract cannot be executed and participation in the study program cannot be enabled. For this purpose, we process the following information from the visa: date of issue, period of validity including expiry date, visa type, and the issuing authority (e.g., responsible consulate). The legal basis for processing is Art. 6 par. 1 (b) GDPR, insofar as processing is necessary for the initiation and execution of the study contract, in particular for checking authenticity and validity in the admission and enrollment process and for ensuring study-related eligibility.
In addition, we process visa data to remind you of upcoming visa renewals and to avoid study-related interruptions due to an expired visa, for study organization, for targeted information and reminders, for internal planning (including assessment of study-related risks due to expiring visas) and to compile aggregated statistics on the basis of Art. 6 par. 1 (f) GDPR. Our legitimate interests are maintaining orderly study operations, avoiding study-related disadvantages, and improving our services, in particular the targeted support of students from certain countries with regard to their residence status and the derivation of trends to which we can respond with our offerings.
Insofar as we are legally obliged in individual cases to provide information to authorities or submit data, we process or transfer the data on the basis of Art. 6 par. 1 (c) GDPR in conjunction with the relevant legal provisions.
Within IU, only those employees who are responsible for admission and enrollment, the student secretariat, and the employees entrusted with visa matters have access to your data. Data will only be transferred to public authorities (e.g., immigration authorities) if there is a legal obligation to do so. Your data will be processed in a CRM solution provided by Salesforce, whose registered office is at Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, England. We have concluded a data processing agreement with Salesforce. The EU Commission has issued an adequacy decision for the UK. To safeguard possible data transfers to the USA, Salesforce is certified under the Data Privacy Framework.
We use a copy of your visa that you submitted, exclusively for authenticity and validity checks and delete it immediately after the check has been completed; no copy is made when the original document is presented on campus. We store the information taken from the visa for applicants who are not enrolled for a maximum of six months after completion of the application process. For enrolled students, the information is stored until they leave the university and for a maximum of twelve months thereafter. Data will only be stored for longer if and as long as this is necessary to assert, exercise, or defend legal claims or if statutory retention obligations prevent deletion.

### 9. Bring a friend

​Through our site, you may recruit friends to study at IU, and receive rewards for doing so. For this purpose, we process your name and email address, as well as the data entered by your friend. You can create a personalized link through our website and send it to your friend. This e-mail contains an affiliate link which contains a pseudonymized referral code in the URL. If your friend clicks on the link, he or she will be taken to a website form for sending information material. The form is used to query whether your friend was recruited by you. The processing is carried out in accordance with Art. 6 par. 1 f) GDPR to pursue our legitimate interest in attracting new customers. The purpose of the processing is to reward customer acquisition. Access to your personal data is granted to employees of IU who are responsible for the customer acquisition program. We process your personal data for the period of time determined by the IU with regard to the performance of the task. We base this on the retention obligations under commercial and tax law.

### 10. Web Analysis Services

​​Our website uses analysis services in order to collect information about our website, provided you have consented to the setting of the corresponding cookies. The data obtained with the help of these analysis services, such as the location of the visitors or their length of stay on our website, gives us information about visitor behaviour on our website. With the help of this data, we can not only eliminate website issues, but also improve the efficiency of our website. Further information on the analysis services used on our website can be found below. For information on the processing of personal data by the cookies set for this purpose, such as the storage duration of the cookies, please refer to our cookie settings
.

#### 10.1 Google Analytics and Google Signals

We use Google Analytics to get an overview of the behaviour of website visitors, and gain insights regarding our digital marketing efforts. Google Analytics allows us to collect and evaluate the data specifically relevant to IU, for example how far down a webpage was scrolled, which button was clicked, etc. Google Analytics also helps us, for example, understand user demographic characteristics such as age, gender and interests, geographic characteristics such as language and location, as well as technical characteristics such as device type, browser and operating system, search history, YouTube history as well as data from Google partner sites. With the help of this data we can not only optimise our website, but can also recognise how the respective user sessions ended (e.g. simple website visit, request for information material, application for studies). Google Analytics also helps us recognise which webpage a user is accessing and via which channel the users come to our website from (e.g. via a paid or unpaid ad, a Google search, a Facebook post or direct access to the website). With the help of this information, IU can identify which marketing channels are working and which are not. Google Analytics also allows us to recognise user paths, i.e. where users are moving on our website, whether they are going back to the start page and how many users access our website. With the help of this information, we can, for example, recognise whether the jumping off of a large number of users is due to a technical defect in the website. The above data gives us a good overview of our website and how it is used. Even if we collect user data, we cannot draw any conclusions about your identity from this data, as we receive reports from Google Analytics that are based on aggregated data sets.

Since we have also activated the Google Signals service offered by Google, i.e. so-called cross-device tracking, your aforementioned data is analyzed across devices and processed for personalizing ads. Google can thus recognize whether you visit our website first via a smartphone and later via a laptop. We ourselves only receive reports with anonymous data from which we can recognize patterns in user behavior. Google Signals is active if you have a Google account and are logged into it when you visit our website. Furthermore, you must have agreed to "personalized advertising" with Google. If you do not want cross-device tracking, you must deactivate "personalized advertising" in your Google account. Google Signals allows us to launch cross-device remarketing campaigns. This means that we also show you our advertising on third-party websites. You may access your data or delete them at Google in “My Activity”.

Information on the provider, the cookies set, the legal basis for cookie collection, international data transfers and storage times of the cookies can be found in our cookie settings
.

#### 10.2 Mouseflow

​​We use Mouseflow to analyse user behaviour on our website, provided you have consented to the setting of the corresponding cookies. Mouseflow observes website users, records session videos and uses these videos to show how users behave on the website (e.g. how far down they scroll). Mouseflow does not collect any clear data for this purpose (e.g. if you enter data in a contact form, Mouseflow does not collect this data because the fields on the contact form are hidden from it). Using Mouseflow, we can also create what is known as heat maps for website use. This is summarised data on all visitors that helps us evaluate scroll, click and mouse behaviour. Mouseflow also shows us exactly at which point in a form users have stopped filling out the form. This user data analysis gives us insights into the use of our website without being able to draw any conclusions about your identity, as we receive reports from Mouseflow based on aggregated data sets.

Information on the provider, the cookies set, the legal basis for cookie collection, international data transfers and storage times of the cookies can be found in our cookie settings
.

#### 10.3 Microsoft Clarity

We use Microsoft Clarity to analyze user behavior on our website, provided that you have consented to the placement of the corresponding cookies. Microsoft Clarity collects interaction data from your visit to our website (such as test data, duration of stay, clicks, or scrolling), diagnostic data, event data, and metadata. We mask URL data; however, personal data may still be processed within referrer URLs if the website includes it in a URL. For more information on data processing, please refer to Microsoft’s documentation at https://learn.microsoft.com/en-us/clarity/setup-and-installation/clarity-data
. Using this data, which we process in pseudonymized form, we gain insights into how our website is used and can take measures to optimize user-friendliness or develop marketing strategies. Additionally, we combine this data with aggregated data from our Google Ads campaigns within Clarity. The legal basis for this data processing is your consent pursuant to Art. 6 para. 1 lit. a) GDPR. Microsoft is certified under the Data Privacy Framework.

Information on the provider, the cookies set, the legal basis for cookie collection, international data transfers and storage times of the cookies can be found in our cookie settings
.

###

### 11. Google Tag Manager

This website uses Google Tag Manager („GTM”), a service provided by Google Ireland Ltd. („Google”), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. Through the use of GTM, tags such as code snippets or pixels are used on our own Website by means of a so-called container, which inserts a kind of placeholder into the source code and in which the tools that are to be used are stored without IU having to interfere with the source code of our Website. Using GTM, tools can be used on our own Website without having to include each of them in the source code. Instead, only the code of GTM has to be included, and then GTM can be used as a central place to launch or disable the desired tools.

GTM works on the Website when a defined user behavior triggers a tag (i.e. a pixel tag, web beacon, or html code) for the tool. GTM collects the relevant data for the built-in tool and forwards it to the tool. Information about the tools used on our Website that are loaded via GTM can be found here
. In this context, not only are the data categories described for the respective tools transferred to the respective tool providers; Google Ireland Ltd. also receives information about your usage behavior on our Website. Since a large number of the tool providers are located in countries outside the EU, please refer to the description of the respective tools if you would like to receive information on the transfer mechanisms agreed with IU. IU has also entered into a data processing agreement with Google Ireland Ltd., which incorporates the EU standard contractual clauses. The main content of this agreement is available for review here: https://policies.google.com/privacy/frameworks?hl=en
.

IU uses GTM to deploy not only statistical tools but also marketing tools. Accordingly, GTM is a statistics and marketing tool, and the use of GTM is based on your consent in accordance with Art. 6(1)(a) GDPR, which you may withdraw at any time with effect for the future by sending an email to datenschutz@iu.org.

### 12. Customer list matching

​We use tools to match customer lists with various advertising providers in order to more specifically target customers who may have an interest in our products. For this purpose, we import a list with names, email addresses, date of birth, gender and, if applicable, address data of our customers into our own advertising account that we have created with an advertising provider, e.g. Facebook, and hash it, i.e. we generate a shorter, numeric value or key with a fixed length. The advertising provider matches this list in the hashed form with its own database and, based on this, selects customers to whom our ads are displayed when they use the advertising provider's products, such as a search engine, a social media platform, a streaming platform or a communication service. In case of a match of customer data, they are added to our account as successfully matched customers.

The legal basis for processing is your consent in accordance with Art. 6 para. 1 a) GDPR. Your personal data in connection with the use of customer list matching with advertising providers will be stored by the respective provider for the duration of the matching of the customer list and is then deleted. IU will use the data for the duration of your consent. At IU, only employees of IU who are responsible for the relevant area have access to your personal data. We currently use the following services:

Google Customer Match: Your personal data will be transferred to Google Ireland Limited, Google Building Gordon House, 4 Barrow Street, Dublin D04 E5W5, Ireland; Alphabet Inc. and Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. To the extent that your personal data is transferred to Google in the USA, this is done on the basis of an agreement that IU has concluded with Google for this purpose and in which the EU standard contractual clauses are included. You can view the main content of the agreement at https://policies.google.com/privacy/frameworks?hl=de
and https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en
. For further information, please visit https://support.google.com/adwordspolicy/answer/6299717?hl=de
. Google's privacy policy can be found at: https://www.google.com/intl/de/policies/privacy/
. You can edit your personal data and privacy settings under Google "My Account": https://myaccount.google.com/intro?hl=de

Facebook Custom Audience: Your personal data will be transferred to Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin, D02, Ireland. Insofar as your personal data is transferred to Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, in the USA, this is done on the basis of an agreement that IU has concluded for this purpose with Facbook or Facebook within the group of companies and in which the EU standard contractual clauses are included. You can view the main content of the agreement at https://www.facebook.com/legal/terms/dataprocessing
and https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en
. Further information is available at https://www.facebook.com/legal/terms/customaudience

Microsoft Customer Match: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. To the extent that your personal data is transferred to the USA, this is done on the basis of an agreement that IU has concluded with Microsoft for this purpose and which incorporates the EU standard contractual clauses. You can view the main content of the agreement at https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA?year=2021
and https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en
. Further information is available at https://privacy.microsoft.com/de-de/privacystatement
.

### 13. Social Media

For the purpose of increasing our reach, we maintain social media online presences on Facebook, Instagram, LinkedIn and YouTube. If you click on a link embedded in our website, you will be redirected to the respective page: Facebook: https://www.facebook.com
, Instagram: https://www.instagram.com
, LinkedIn: https://de.linkedin.com
, YouTube: www.youtube.com
. Plugins of these social networks are integrated on our website. When you visit our website, a direct connection between your browser and the server of the social network is established via the plugins. The social network thereby receives the information that you have visited this website with your IP address. If you are logged into your account with the social network, the social network can assign the visit to this website to your user account. Details on data collection (purpose, scope, further processing, use) as well as your rights and setting options can be found in the privacy policy of the social network. The deletion of your personal data by the social network takes place as described in the respective privacy policy. If there is joint responsibility with Instagram or Facebook, the contract on joint responsibility applies. You can find the contract at https://de-de.facebook.com/legal/terms/page_controller_addendum
. For more information on the respective responsibilities, please refer to the Facebook Page Insights Supplement (https://de-de.facebook.com/legal/terms/page_controller_addendum
). The legal basis for the processing of the data is Art. 6 para. 1 f) GDPR. Our legitimate interest in this respect is to increase the reach of our online presence on the social media channels. The purpose of the processing is to increase our presence on the Internet. Access to the data is granted to employees of IU who are active in the support of the social media channels and, if applicable, to employees of the respective provider. Your personal data is transferred to the companies listed below in the USA or can be accessed from there. For more information on safeguarding the international transfer of data, please refer to the section "Transfers of personal data to third countries". Information on data processing can be found at: LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy https://www.linkedin.com/legal/privacy-policy
, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
, Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) - Privacy Policy/Opt-Out: http://instagram.com/about/legal/privacy
. Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland) - Privacy Policy (Opt-Out: https://www.facebook.com/about/privacy/legal_bases
). YouTube (Google Ireland Limited Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, Privacy Policy: https://policies.google.com/privacy
, Opt-Out: https://adssettings.google.com/authenticated
.). We process your personal data for the duration determined by the IU with regard to the performance of the task. In this regard, we take the retention obligations under commercial and tax law as a basis. Clicking on a link, such as to Facebook, Instagram, Twitter, YouTube, TikTok or LinkedIn, will take you to the respective websites of the different providers. Data processing on the respective website is governed by the data protection information applicable there. The IU has no influence on the data processing carried out there.

### 14. Cloudinary

​​On our Website we use a so-called Content Delivery Network („CDN“) of Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA („Cloudinary“). A CDN is an online service that is used in particular to load large media files (such as graphics, page content or scripts) through a network of regionally distributed servers connected via the Internet and display them on our Website. The use of the CDN helps us to optimize the loading speeds of our Website.

The processing takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in a secure and efficiently functioning website as well as the improvement of the stability and functionality of our Website.

We have concluded a data processing agreement with Cloudinary (Data Processing Addendum, available at https://cloudinary.com/gdpr/dpa
, which incorporates the EU standard contractual clauses.

Further information can be found in Cloudinary’s privacy notice at https://cloudinary.com/privacy
.

### 15. Survey questions on the website

​​When visiting our Website, we may ask you via a window that opens whether you already knew us before visiting our Website. For this purpose, we collect the data specified in the Server Log Files. If you answer the question, we also process your answer. This information is evaluated in aggregated form on the basis of our legitimate interest in being able to track the effectiveness of our marketing measures in accordance with Art. 6(1)(f) GDPR.

We retain information in this context for the duration specified by IU in order to perform the task and delete the data thereafter.

### 16. Rights of data subject

​You can contact IU in writing or per email at datenschutz@iu.org in order to exercise the following rights:

- Access your data in order to check and verify this data;

- Obtain a copy of your personal data;

- Rectification, erasure or restriction of processing, which also includes the right to complete incomplete or incorrect data by providing a supplementary statement;

- Right to object to the processing; please note that pursuant to Art. 21 GDPR you have the right to object to the processing of personal data processed by us on the basis of legitimate interests pursuant to Art. 6 (1) (f) DSGVO; you have a right to object to processing insofar as this is done on grounds relating to your particular situation; insofar as the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right to object without the requirement to specify a particular situation,

- You can receive your provided personal data in a structured, commonly used and machine-readable format and transmit this data to another controller, provided that you have given your consent to the processing or the processing is based on a contract;

- If you have given us your consent to process your personal data, you can withdraw this consent at any time with effect for the future.

You also have the right to lodge a complaint with a supervisory authority with regard to the processing of your personal data. To exercise this right, you can contact the authority responsible for your place of residence or for the location of the IU in Thuringia:

Der Thüringer Landesbeauftragte für den Datenschutz, Häßlerstraße 8, 99096 Erfurt, or in case of complaint concerning the data processing through IU Health, you may contact: Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz, Hintere Bleiche 34, 55116 Mainz.

### 17. Automated decision-making and profiling

​Except for the services described in the context of Google Analytics and Google Signals, your personal data will not be used by IU for automated decision-making.

When visiting our Website, we place cookies from various providers, provided you have given your consent in this regard. By means of the cookies that you have allowed in each case, data is generated as described in the Server Log Files. This data is consolidated and combined by IU with the help of a Google solution. For this purpose, IU has concluded a data processing agreement with Google, with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland, which incorporates the EU standard contractual clauses. If we receive information about you through our Website, for example, because you ask us to send you informational materials or contact us, then we store your data and combine it with the data generated by cookies. In addition, we receive reports from Google Analytics with data that we also combine with your data. For further information, please refer to the section on Google Analytics.

With the help of your consent regarding the data generated via our website, we store it in a CRM solution. We analyze the data to determine whether you are only interested in a course of study offered by us or whether you have also applied, and we add the relevant information to your data record. We store this profile created about you in a salesforce solution provided by Salesforce, with its registered office at Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, England.

The legal basis for this data processing is your consent in accordance with Art. 6(1)(a) GDPR, which you can withdraw at any time with effect for the future by contacting datenschutz@iu.org.

### 18. Why do we collect your personal data?

​​You may choose not to provide us with your personal data or choose to provide incomplete data. In such a case, for example, if you prevent the storage of a cookie, you may not be able to use all the functionalities of the Website.

18.1 In the course of a study application procedure or an application for a job

​If you do not provide us with your personal data or only provide us with incomplete personal data in the context of an admission procedure or a job application, we may not be able to accept you as a student or offer you the opportunity to participate in a job application procedure.

18.2 In the course of the purchasing process

​If you do not provide us with your personal data or only provide us with incomplete personal data in the context of an purchasing process, we may not be able to purchase you a licence or a training.

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