The following information shall inform Bertelsmann applicants of the Bertelsmann Scholarship Program, together with Udacity about how Bertelsmann and in certain parts of the processing Udacity processes personal data. This information serves to comply with the duties imposed under the General Data Protection Regulation (GDPR).

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

Bertelsmann SE & Co. KGaA

Department: Bertelsmann University

Carl-Bertelsmann-Straße 270 33311

Gütersloh Tel: +49 (0) 5241-80-0

Fax: +49 (0) 5241-80-62321

E-mail: university@@bertelsmann..com

(hereinafter „Bertelsmann“)

is responsible for the following data processing. We process personally identifiable information (“personal data”) in accordance with GDPR provisions and the German Federal Data Protection Act (BDSG).

You can contact the designated Data Protection Officer of Bertelsmann at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: datenschutz@bertelsmann.de.

2. Which data are used for which purpose? 

The Parties use your data for the following purposes: 

2.1 Submission of the application form and selection procedure

2.1.1 Description and extent of the processing 

For the application of the participants to the Bertelsmann Scholarships, that are employed by any Bertelsmann Group Company, Bertelsmann designs application forms that must be completed by the potential participants. Data usually processed within the application forms are name, surname, country participant is currently living or working from, peoplenet ID, age greater than 18, English language proficiency, motivational questions and technical prerequisites questions where applicable etc. These are used to then select a range of potential participants for the Bertelsmann Scholarship.

2.1.2 Purposes and legal basis for the use of personal data 

The legal basis for collecting and processing your data in the application and selection process is the performance of the contract Art. 6 (1) b GDPR. If individual data collection or processing is based on consent in the application form, consent Art. 6 (1) a GDPR is the applicable legal basis in these specific cases. Some data and information within the application form may be collected on the basis of legitimate interests Art. 6 (1) f, such as the peoplenet ID.

2.1.3 Duration of storage 

Your data is usually retained no longer than necessary for the purposes for which it is processed. Usually once the Scholarship and all related circumstances to the Scholarship which require further processing of your data are completed, your data will be deleted. This does not apply if legal retention periods require further storage of your data.

2.1.4 Right to object 

You may withdraw your consent at any time with future effect by notifying the company of your withdrawal via university@bertelsmann.com with the subject "Withdrawal consent". If your data is processed on the basis of a legitimate interest pursuant to Art. 6 (1) (f) GDPR, you can object to the processing of your data at any time for reasons arising from your particular situation by sending an e-mail to university@bertelsmann.com. This does not apply if the storage of your application data is necessary for completing precontractual procedures or fulfilling a contract.

2.2.Upload of the scholarship participation/completion to the learning plan and learning history on peoplenet

2.2.1 Description and extent of the processing 

As part of their application for the Bertelsmann Scholarship Program, participants have to indicate their peoplenet ID if they are employees of the Bertelsmann Group. The peoplenet ID provided, their participation in the scholarship program is added to the learning plan and learning history in the peoplenet employee profile. The learning plan/learning history is only visible to the employee, their manager, the responsible HR department and Bertelsmann University.

2.2.2 Purposes and legal basis for the use of personal data 

The data processing is required for the support and development of participants during the scholarship program. The legal basis for uploading the scholarship program is Art. 6 (1) lit. f DSGVO. 

2.1.3 Duration of storage 

Your data is usually retained no longer than necessary for the purposes for which it is processed. The information on the completion or non-completion of the Scholarship is deleted within the peoplenet training plan and history at the latest upon leaving the Bertelsmann Group and at the earliest upon objection to the processing or as soon as the purpose of processing has ceased.

2.2.4 Right to object 

If your data is processed on the basis of a legitimate interest pursuant to Art. 6 (1) (f) GDPR, you can object to the processing of your data at any time for reasons arising from your particular situation by sending an e-mail to university@@bertelsmann..com.

2.3 Course progress transmission 

2.3.1 Description and extent of the processing 

During the learning process for the Scholarship Program, the course progress will be evaluated by Bertelsmann, if the participants are employees of the Bertelsmann Group Companies. Participants can provide their consent for the transmission of their individual course progress if they are employees of the Bertelsmann Group to their respective HR department of the Bertelsmann Group Company. If consent is given, course progress information, including your first and last name, will be transmitted to the respective and responsible HR department during the scholarship program. This information is voluntary, and your course progress is generally only visible to you, Bertelsmann University and your respective and responsible HR department. The HR Departments might reach out for supporting purposes with the courses and Scholarship in general.

2.3.2 Purposes and legal basis for the use of personal data 

The legal basis for collecting and processing your data for the realization of the Scholarship is the performance of the contract Art. 6 (1) b GDPR. The data processing is required for the support and development of participants during the scholarship program. The legal basis for forwarding the course progress of the scholarship program to the HR departments for contacting and supporting purposes is Art. 6 (1) a GDPR. 

2.3.3 Duration of storage 

Your data are usually retained no longer than necessary for the purposes for which it is processed. The data will be stored for the duration of the scholarship program. Regarding the retention of the completion or non-completion status within peoplenet see 2.1.3. After the end of the scholarship program, the data will be stored exclusively to give evidence that the company has obtained your consent for the processing of the data. 

2.3.4 Right to object 

You may withdraw your consent at any time with future effect by notifying the company of your withdrawal via university@bertelsmann.com with the subject "Withdrawal consent". This does not apply if the storage of your application data is necessary for completing precontractual procedures or fulfilling a contract.

2.4 Reporting

2.4.1 Description and extent of the processing 

The data collected during the application and learning process and progress is evaluated by Bertelsmann as part of reporting. The pseudonymized reports are then part of the reporting to the board of directors.

2.4.2 Purposes and legal basis for the use of personal data 

The data processing is required for the support and development of participants during the scholarship program and for further planning and improvement of upcoming Scholarships. The legal basis for uploading the scholarship program is Art. 6 (1) lit. f DSGVO. 

2.4.3 Duration of storage 

Your data is usually retained no longer than necessary for the purposes for which it is processed. The reports are pseudonymized and are therefore kept until an evaluation of the previous results and circumstances in connection with the scholarships no longer represent a value for future planned Scholarships. Regarding the duration of storage and deletion to the data processed within the Scholarship programs, which build the basis of the reports, please see 2.1.3, 2.2.3., 2.3.3. 

2.4.4 Right to object 

If your data is processed on the basis of a legitimate interest pursuant to Art. 6 (1) (f) GDPR, you can object to the processing of your data at any time for reasons arising from your particular situation by sending an e-mail to university@@bertelsmann..com.

2.5. Questionnaires regarding existing prior knowledge and self-assessment of own performance

2.5.1 Description and extent of the processing

Within the Bertelsmann Scholarship Program, together with Udacity, participants are asked to answer certain questions in a questionnaire for the purpose of self-assessment of their own pre-existing knowledge. During the course of the scholarship, as well as after its completion, questionnaires are also provided, which are intended to provide a self-assessment and knowledge acquisition on the part of the participants. The results of the questionnaires will afterwards be analyzed and evaluated. The reports are pseudonymized in such a way that Bertelsmann only has access to aggregated data, without any possibility of identifying or tracing individual participants or their specific skills. It is also not in Bertelsmann's interest to establish a personal reference with regard to those analysis.

2.5.2 Purposes and legal basis for the use of personal data 

The data processing is required for the support and development of participants’ skills during the scholarship program and for further planning and improvement of upcoming Scholarships. The legal basis for the analyses and evaluation within the scholarship program is Art. 6 (1) lit. f DSGVO.

2.5.3 Duration of storage 

Your data are usually retained no longer than necessary for the purposes for which it is processed. The reports are pseudonymized and are therefore kept until an evaluation of the previous results and circumstances in connection with the scholarships no longer represent a value for future planned Scholarships. Regarding the duration of storage and deletion to the data processed within the Scholarship programs, which build the basis of the reports, please see 2.1.3, 2.2.3., 2.3.3.

2.5.4 Right to object 

If your data is processed on the basis of a legitimate interest pursuant to Art. 6 (1) (f) GDPR, you can object to the processing of your data at any time for reasons arising from your particular situation by sending an e-mail to university@@bertelsmann..com.

2.6. Waiting list

2.6.1 Description and extent of the processing

As part of the participation in the Scholarship Program, applicants may be placed on a waiting list if all available spots are already taken and they have given their consent to be included in this list. In this case, we may share certain personal data of the applicant, specifically the applicant’s name, e-mail address, and peoplenet ID, with the applicant’s respective HR department within the Bertelsmann Group. The HR department may contact the applicant for support and/or development purposes related to the Scholarship Program.

2.6.2 Purposes and legal basis for the use of personal data 

The processing of personal data in this context serves to enable HR departments to identify and support employees who are interested in participating in the Scholarship Program and have been placed on the waiting list. The legal basis for this processing is your consent Article 6 sec. 1 lit. a GDPR as the applicant voluntarily agrees to the sharing of their personal data by selecting the corresponding consent option in the application process.

2.6.3 Duration of storage 

Personal data shared for the purpose of waiting list management will be retained only for as long as necessary to administer the waiting list and related HR support or development activities. Once the waiting list period has ended and the selection process is completed, the data will be deleted, unless further storage is required by applicable retention obligations or based on withdrawal of consent by the applicant.

2.6.4 Right to object 

You may withdraw your consent at any time with future effect by notifying the company of your withdrawal via university@@bertelsmann..com with the subject "Withdrawal consent". 

3. Who obtains your data? 

Within Bertelsmann only those departments will have access to your data who need them in order to fulfil the purposes outlined in section 2. Service providers used by the company may also receive access to your data (so-called "order processors", e.g. data centers, web tracking). Via Data Protection Agreements, the binding of instructions, the data security and the confidential handling of your data by these service providers are ensured. 

4. Is your data transferred outside of the EU (Third country transfer)? 

Service providers used for the technical provision of IT systems for the communication of the recipients named in Section 3 and for the transfer of data may be located outside the European Union or the European Economic Area ("EU" or "EEA"). By concluding standard contractual clauses or within the scope of an applicable adequacy decision, it is ensured that the European level of data protection is guaranteed with service providers used for the third country transfer. You can request a copy of this guarantee from us using the contact details provided in section 1. 

5. What are your rights? 

You have all rights under Chapter III of the GDPR. They can be exercised towards every Controller handling your data. These rights are: 

• Right to access: You can request information about all data stored about you and how they are processed by the accountable Controller. 
• Rectification: You can request rectification, where data concerning you are wrong or outdated. 

• Erasure and to be forgotten: You can request that the Controller deletes your data. Where a deletion is conducted, the Controller shall inform any recipient about that to whom the data have been disclosed (Right to be forgotten). 
• Restriction: You can request a restriction of the data for the reasons set out by GDPR. 
• Data Portability: Where the conditions of the law are met, you can request to receive a copy of your data in a structured, machine readable and commonly used format. 
• Object: You can object the processing of your data for reasons that relate to your particular situation, if the processing is based on Art. 6 (1) lit. f – legitimate interests – GDPR. 

If you have given us your consent for the processing of your data, you can withdraw this consent with effect for the future, at any time. Please address your withdrawal to the attention of our Data Protection Officer indicated in Sec. 1 above. 

Your rights also apply to the above indicated cookies. 

You also have the option of contacting a data protection authority and lodging a complaint there.

The authority responsible for Bertelsmann is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestr. 2-4 40213 Düsseldorf E-mail: poststelle@@ldi.nrw..de.

You can also contact the data protection authority responsible for your place of residence. 

6. From where is your data collected? 

All data processed by us for the purposes indicated above (see section 2) are directly collected from you. We hereby provide you with the mandatory information pursuant to Art. 13 GDPR.

7. Is there any automated decision-making (including profiling)? 

For the purposes indicated in Section 2 above, we do not use automated decision making (including profiling). 

8. Final information / Version 

This document is subject of constant improvement and change. This may affect the given information about any processing of personal data.