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Privacy Policy

With this Privacy Policy, we provide information about the processing of personal data in connection with our activities and operations, including our website under the domain name international-learning-group.com. In particular, we provide information on what, how, and where we process personal data. We also provide information about the rights of persons whose data we process.

For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.

We are subject to Swiss law as well as any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

By decision of 26 July 2000, the European Commission recognized that Swiss data protection law ensures an adequate level of data protection. In a report dated 15 January 2024, the European Commission confirmed this adequacy decision.

Table of Contents

1. Contact Addresses

The party responsible for data protection is:

Aelmans, Nico
nico.aelmans@international-learning-group.com

In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. We are happy to provide information to data subjects about the respective responsibility upon request.

2.1 Terms

Data Subject: A natural person about whom we process personal data.

Personal Data: Any information relating to an identified or identifiable natural person.

Sensitive Personal Data: Data about trade union, political, religious or philosophical beliefs and activities; data about health, privacy, or affiliation with an ethnic group or race; genetic data; biometric data that uniquely identifies a natural person; data about criminal and administrative sanctions or prosecutions; and data about social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading out, disclosing, obtaining, recording, collecting, deleting, organizing, saving, modifying, distributing, linking, destroying, and using personal data.

European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (FADP) and the Data Protection Ordinance (DPO).

Insofar as and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data according to at least one of the following legal bases:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data to fulfill a contract with the data subject and to carry out pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to safeguard legitimate interests—including those of third parties—unless the fundamental freedoms and rights as well as interests of the data subject prevail. Such interests include, in particular, the permanent, human-friendly, secure, and reliable exercise of our activities and operations, ensuring information security, protection against misuse, enforcement of our own legal claims, and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data to perform a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
  • Art. 9 para. 2 et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subject.

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as “processing of personal data” and the processing of sensitive personal data as “processing of special categories of personal data” (Art. 9 GDPR).

3. Nature, Scope, and Purpose of Processing Personal Data

We process the personal data that is necessary to perform our activities and operations permanently, human-friendly, securely, and reliably. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities and operations, provided that such processing is permissible.

We process personal data, if necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to fulfill legal obligations or to safeguard overriding interests. We may also request consent from data subjects even if their consent is not required.

We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data, in particular depending on statutory retention and limitation periods.

4. Disclosure of Personal Data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may be, for example, specialized providers whose services we use.

In the context of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

5. Communication

We process personal data in order to communicate with individuals as well as with authorities, organizations, and companies. In doing so, we process in particular data that a data subject transmits to us when contacting us, for example by letter or email. We may store such data in an address book or using comparable tools.

Third parties who transmit data about other persons to us are obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that such data is accurate and may be transmitted.

6. Applications

We process personal data about applicants to the extent necessary to assess their suitability for employment or for the subsequent execution of an employment contract. The required personal data arises in particular from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and print media or on job portals and job platforms.

Furthermore, we process personal data that applicants voluntarily communicate or publish, in particular as part of cover letters, CVs, and other application documents as well as online profiles.

Insofar as and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular in accordance with Art. 9 para. 2 lit. b GDPR.

7. Data Security

We take appropriate technical and organizational measures to ensure a level of data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the processed personal data, although we cannot guarantee absolute data security.

Access to our website and our other digital presence is carried out using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.

Our digital communication—like principally all digital communication—is subject to mass surveillance without cause and suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot exert any direct influence on the corresponding processing of personal data by intelligence services, police departments, and other security authorities. We also cannot exclude the possibility that a data subject is specifically monitored.

8. Personal Data Abroad

We principally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other states, in particular to process it there or have it processed there.

We may export personal data to all countries on Earth and elsewhere in the Universe, provided that the law there ensures adequate data protection according to the decision of the Swiss Federal Council and—if and to the extent the General Data Protection Regulation (GDPR) is applicable—also according to the decision of the European Commission.

We may transmit personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. We are happy to provide information to data subjects upon request about any guarantees or provide a copy of any guarantees.

9. Rights of Data Subjects

9.1 Data Protection Claims

We grant data subjects all claims in accordance with applicable law. Data subjects have the following rights in particular:

  • Access: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
  • Rectification and Restriction: Data subjects may have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.
  • Possibility for own point of view and human review: In the case of decisions based exclusively on automated processing of personal data and which have legal consequences for them or significantly affect them (automated individual decisions), data subjects may state their own point of view and request a review by a human being.
  • Erasure and Objection: Data subjects may have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data Disclosure and Data Portability: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may postpone, restrict, or refuse the exercise of the rights of data subjects within the legally permissible framework. We may inform data subjects of any requirements that must be met in order to exercise their data protection claims. For example, we may refuse access in whole or in part by citing confidentiality obligations, overriding interests, or the protection of other persons. We may also, for example, refuse the deletion of personal data in whole or in part by citing statutory retention obligations.

We may exceptionally provide for costs for the exercise of rights. We inform data subjects in advance about any costs.

We are obliged to identify data subjects who request information or assert other rights using appropriate measures. Data subjects are obliged to cooperate.

Data subjects have the right to enforce their data protection claims through legal action or to lodge a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are structured federally, particularly in Germany.

10. Use of the Website

10.1 Cookies

We may use cookies. Cookies—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies make it possible, in particular, to recognize a browser the next time you visit our website and thereby, for example, measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated, restricted, or deleted in the browser settings at any time. Browser settings often also allow for the automated deletion and other management of cookies. Without cookies, our website may no longer be available in its full scope. We ask—at least if and to the extent required by applicable law—actively for express consent to the use of cookies.

For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for many services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

10.2 Logging

We may log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted to our digital infrastructure as standard during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including the amount of data transferred, last webpage accessed in the same browser window (referer or referrer).

We log such information, which may also constitute personal data, in log files. The information is necessary to provide our digital presence permanently, human-friendly, and reliably. The information is also necessary to ensure data security—also by third parties or with the help of third parties.

10.3 Tracking Pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when accessing our digital presence. Tracking pixels can collect at least the same information as logging in log files.

11. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested parties and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and Terms of Use as well as privacy policies and other provisions of the individual operators of such platforms also apply in each case. These provisions provide information in particular about the rights of data subjects directly against the respective platform, which includes, for example, the right of access.

For our social media presence on Facebook, including the so-called Page Insights, we are—if and to the extent the General Data Protection Regulation (GDPR) is applicable—jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook effectively and in a human-friendly manner.

Further information about the nature, scope, and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook as well as Facebook’s data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called “Controller Addendum” with Facebook and have thereby agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page “Information about Page Insights” including “Information about Page Insights Data”.

12. Third-Party Services

We use services from specialized third parties to perform our activities and operations permanently, human-friendly, securely, and reliably. With such services, we can, among other things, embed functions and content into our website. In the case of such embedding, the services used capture the IP addresses of the users for technically mandatory reasons, at least temporarily.

For required security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to offer the respective service.

We use in particular:

12.1 Digital Infrastructure

We use services from specialized third parties in order to make use of the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

We use in particular:

12.2 Appointment Scheduling

We use services from specialized third parties to schedule appointments online, for example for meetings. In addition to this Privacy Policy, any conditions of the services used that are directly visible, such as terms of use or privacy policies, also apply.

12.3 Audio and Video Conferencing

We use specialized services for audio and video conferencing in order to communicate online. We can use them, for example, to hold virtual meetings or conduct online classes and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, apply additionally.

Depending on your personal situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or having a virtual background displayed.

We use in particular:

12.4 Online Collaboration

We use third-party services to enable online collaboration. In addition to this Privacy Policy, any conditions of the services used that are directly visible, such as terms of use or privacy policies, also apply.

12.5 Social Media Functions and Social Media Content

We use services and plugins from third parties to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and via other channels.

12.6 Map Material

We use third-party services to embed maps into our website.

We use in particular:

12.7 Fonts

We use third-party services to embed selected fonts as well as icons, logos, and symbols into our website.

We use in particular:

13. Extensions for the Website

We use extensions for our website to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure.

We use in particular:

14. Performance and Reach Measurement

We attempt to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party references or test how different parts or versions of our digital presence are used (“A/B test” method). Based on the results of the performance and reach measurement, we can, in particular, fix errors, strengthen popular content, or make improvements.

In most cases, the IP addresses of individual users are collected for performance and reach measurement. In this case, IP addresses are principally shortened (“IP masking”) in order to follow the principle of data minimization through the corresponding pseudonymization.

Cookies may be used and user profiles may be created for performance and reach measurement. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the—at least approximate—location. Principally, any user profiles are created exclusively on a pseudonymized basis and are not used to identify individual users. Individual third-party services where users are logged in may be able to assign the use of our online offering to the user account or user profile of the respective service.

We use in particular:

  • Google Tag Manager: Integration and management of services from Google and third parties, in particular for performance and reach measurement; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.

15. Final Notices Regarding the Privacy Policy

We have created this Privacy Policy with the Privacy Generator from Datenschutzpartner .

We may update this Privacy Policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current Privacy Policy on our website.