The following information informs Bertelsmann employees who apply for or participate in the Bertelsmann Scholarship 2027 (Coursera license and personal AI learning agent, the "Program") about how Bertelsmann and – for certain parts of the processing – Coursera process personal data. It serves to comply with Art. 13 and 14 GDPR. It is provided for your information; it does not require your consent.

1. Who is responsible for the use of your data?

Bertelsmann SE & Co. KGaA, Department Bertelsmann University, Carl-Bertelsmann-Straße 270, 33311 Gütersloh, Germany, E-mail: university@bertelsmann.com ("Bertelsmann") is responsible for the processing described in Sections 2.1 to 2.5.

Coursera, Inc., 381 E Evelyn Ave., Mountain View, CA 94041, USA, E-mail: privacy@coursera.org ("Coursera") is separately responsible for the processing on the Coursera learning platform (your Coursera account, your learning activity on the platform). Coursera's privacy notice: de.coursera.org/about/privacy.

Bertelsmann and Coursera act as separate controllers. Processing not described in this notice is the sole responsibility of Coursera.

You can contact Bertelsmann's Data Protection Officer at the address above ("For the attention of the Data Protection Officer") or at datenschutz@bertelsmann.de.

2. Which data are used for which purpose?

2.1 Application and selection

What we process: first name, last name, business e-mail address, job title, Levio employee ID, country, division, whether you have a Microsoft Copilot license, your motivation, two main tasks of your role and how often you use AI for them, and your confirmations in the application form. The form is provided by our service provider Lamapoll (Lamano GmbH & Co. KG, Berlin) on our behalf.

Purpose and legal basis: to process your application, select participants and plan the cohorts of the Program (Art. 6(1)(b) GDPR – steps prior to and performance of the participation agreement; for employees of German group companies also § 26(1) BDSG). We also check your executive status in Levio: executives do not take part in the 2027 pilot, because the learning content is tailored to other roles. Selection is made by Bertelsmann University staff; no automated decision-making and no AI is used for the selection. Your answers about your tasks and AI use are used to plan the Program (e.g. to balance the cohort); they are not shared with your manager or HR.

Retention: application data of participants are kept for the duration of the Program and deleted twelve months after its end; until then, division, job title and main tasks are evaluated only in aggregated form for planning future cohorts (Section 2.5). Data of applicants who do not receive a seat are deleted six months after the selection has been completed, unless you have been placed on the waiting list (Section 2.4) or statutory retention periods apply.

2.2 Participation: Coursera license and personal AI learning agent

What we process: your enrollment data (name, Levio ID, e-mail address) transmitted to Coursera to activate your license. For the AI learning agent we take over from your application and from Levio your Levio ID, division and job title and whether you have management responsibility. Within the agent we process your selection of function, main activities and tasks, your skill reflection based on predefined statements, the resulting assessment of your AI usage profile and skills (including later changes to your answers), learning recommendations, your interactions with the agent, your course completions (received from Levio, see 2.3) and your answers in the post-assessment. From Coursera's reports we also receive your learning time on the platform.

How the agent arrives at its assessment: the agent runs in Microsoft 365 Copilot or Microsoft Teams. It assigns your answers to an AI usage profile using defined criteria and determines, using a defined scoring logic, which AI skills are most relevant for you next. The profile itself is not shown to you; it only determines which skills and courses are suggested to you. If the suggestions do not fit, you can change your answers and your skill reflection or repeat them at any time; the recommendations then adjust. On request we tell you which profile you have been assigned to (Art. 15 GDPR). The agent uses AI to conduct the dialogue and to suggest courses. This assessment is profiling (Art. 4(4) GDPR): it is used solely to give you suitable learning recommendations, all courses remain available to you regardless, and it has no effect on your employment. No automated decision within the meaning of Art. 22 GDPR takes place.

Purpose and legal basis: to provide the Program to you – the license and a personalised learning journey (Art. 6(1)(b) GDPR; § 26(1) BDSG). The learning agent is an AI system; you are informed when you interact with it (Art. 50 EU AI Act). It supports your learning; it does not evaluate you as an employee, does not certify skills and takes no decision with legal or similarly significant effect on you.

Who can see these data: you; Bertelsmann University program administration to the extent necessary to run the Program and to support you; our technical service providers (Section 3). Not your employer, your manager or HR (see 2.3 for what they do receive).

Retention: learning agent data are pseudonymised at the end of the Program and deleted or anonymised twelve months later (see 2.5). If you want to build on your previous status when you take part again, you can give separate consent in the post-assessment for your data in the agent or a successor solution provided by BU to be kept under your Levio ID for up to 24 months after the end of the Program (Art. 6(1)(a) GDPR); they then remain visible only to you and the program administration. You may withdraw this consent at any time with effect for the future by e-mail to university@bertelsmann.com; the first sentence then applies. For data processed by Coursera on its platform, see Coursera's privacy notice.

2.3 Learning history in Levio and information to your employer

What we process: your participation status in the Program (applied, selected, waiting list, started, ended), the courses and programs in which you are enrolled, your progress status per course (e.g. progress in per cent, where the learning provider reports it), and your completed courses with the course duration set by the learning provider (not your actual learning time).

Purpose and legal basis: these data are recorded in your learning plan and learning history in Levio, the learning system of the Bertelsmann Group, and are thereby available to the HR department of the Bertelsmann Group company that employs you, as documentation of your professional development (legitimate interest of Bertelsmann and of your employer in documenting training within the Group and in administering the licenses and seats provided, Art. 6(1)(f) GDPR; for your employer also § 26(1) BDSG). In Levio, you, your responsible HR department and Bertelsmann University see these data; your manager sees your completed courses. On this basis your HR department may contact you about the Program, for example to offer support. These data are not used to assess your work performance and not for objectives or personnel decisions. Your employer processes them under its own responsibility as part of your personnel and training records; Bertelsmann and your employer are separate controllers in this respect.

What is not transferred: your questionnaire answers, your skill reflection, the resulting assessment of your AI usage profile and skills, learning recommendations, your interactions with the AI learning agent, your answers in the post-assessment (Section 2.2) and your actual learning time. Bertelsmann University uses these data only as described in Section 2.5.

Right to object: you may object to this transfer at any time for reasons arising from your particular situation (Art. 21 GDPR) by e-mail to university@bertelsmann.com.

Retention: entries in Levio are kept until you leave the Bertelsmann Group, or until your objection has been accepted.

2.4 Waiting list (optional, consent)

If all seats are taken, you may be placed on a waiting list. If you tick the corresponding optional box, Bertelsmann University shares your name, business e-mail and Levio ID with your HR department so that HR can contact you about alternatives (Art. 6(1)(a) GDPR). You may withdraw your consent at any time with effect for the future by e-mail to university@bertelsmann.com. Waiting-list data are deleted when the waiting list is closed, at the latest twelve months after the program ends.

2.5 Evaluation and further development of the Program

We evaluate the Program to demonstrate its benefit, to steer it and to plan future cohorts, and we further develop the AI learning agent. Your employer, your manager and HR never see your individual answers.

What is evaluated: the number of applicants and participants, completion rates, which courses are used, which job titles with which main tasks take part, and the development of AI skills between your skill reflection at the start and in the post-assessment ("impact measurement").

Reports: so that the before/after comparison is accurate, your data in the agent, your course completions and your division and job title are linked automatically via your Levio ID within Bertelsmann's IT environment. Reports contain only totals and averages for groups of at least five persons per division and, as soon as results are broken down by job role (grouped job titles), of at least ten persons – also where several characteristics are combined; results are never broken down further than by division and job role. Reports go to the divisional learning and development teams, to the Bertelsmann University program team and to Group committees such as the Executive Board.

Further development of the AI learning agent: so that the agent becomes more accurate, a designated group of Bertelsmann University staff checks, already during the Program, whether the profile assignment and scoring logic are consistent. For this purpose, the group sees your data in the agent and your course data including learning time only without your name and Levio ID. It does not belong to HR, does not pass on individual data and makes no attempt to identify anyone. Twelve months after the end of the Program the data are deleted or anonymised.

Individual results – such as your skill reflection, the agent's assessment or your learning time – are not given to your employer, your manager or HR; they are not used to assess your work performance.

Why you can answer honestly: your skill reflection serves you first – the more accurate your answers, the better the learning recommendations fit. In reports it only appears as part of a group value, and for the further development only without your name.

Legal basis: legitimate interest in evaluating, steering and developing our learning programs (Art. 6(1)(f) GDPR). This is not necessary for your participation itself; we therefore do not base it on the participation agreement. You may object for reasons arising from your particular situation (Art. 21 GDPR) by e-mail to university@bertelsmann.com; your data will then not be included.

Coursera is not responsible for Bertelsmann's reporting.

3. Who receives your data?

Within Bertelsmann, only Bertelsmann University staff who need your data for the purposes in Section 2 have access. They receive reports under Section 2.5 in aggregated form only; only the group named there sees the pseudonymised data for the further development of the agent. The following service providers process data on our behalf as processors under data processing agreements (Art. 28 GDPR):

• Lamano GmbH & Co. KG (Lamapoll), Berlin – application forms; hosted in data centres in Germany;
• The Boston Consulting Group GmbH, Düsseldorf – development, testing and support of the AI learning agent – exclusively within Bertelsmann's IT environment; real data only for tests under a documented test plan, deleted afterwards and set-up of the automated evaluation under Section 2.5;
• Microsoft – platform for the AI learning agent in the Bertelsmann tenant (Microsoft 365 Copilot, Teams, Copilot Studio, Dataverse, Power Automate)
• SAP (SuccessFactors) – technical basis of the group learning system Levio.

Your employer's HR department receives the data described in Section 2.3 (and, with your consent, 2.4). Coursera receives your enrollment data and processes your platform activity as a separate controller.

4. Is your data transferred outside the EU/EEA?

Coursera is located in the USA; your enrollment data are transferred to Coursera on the basis of the EU-U.S. Data Privacy Framework certification of Coursera, Inc. / EU Standard Contractual Clauses . Service providers used for the AI learning agent may have access from outside the EU/EEA; in these cases the European level of data protection is ensured by EU Standard Contractual Clauses or an adequacy decision BCG UK LLP: UK adequacy decision; Microsoft: SCC/DPF. You can request a copy of the safeguards via the contact details in Section 1.

5. What are your rights?

You have the rights under Chapter III GDPR towards each controller: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), objection to processing based on legitimate interests (Art. 21, see 2.3 and 2.5) and withdrawal of consent (Art. 7(3), see 2.2 and 2.4). You may also lodge a complaint with a supervisory authority; for Bertelsmann SE & Co. KGaA this is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen. To exercise your rights towards Bertelsmann, write to university@bertelsmann.com or datenschutz@bertelsmann.de; towards Coursera, see de.coursera.org/about/privacy. Submitted application forms cannot be edited by you; to correct information, contact university@bertelsmann.com.

6. Co-determination

The AI learning agent is introduced in 2027 as a pilot, on the basis of the Group works agreement on the use of IT solutions in pilot projects of 14 March 2019 as amended on 14 March 2024; the Group Works Council tolerates the pilot including the application questionnaire. A works agreement will be concluded after the pilot.